RE: Agency Information Collection Activities; Submission for OMB Review; Comment Request; Revision of a Currently Approved Collection (ICR Rev); National Survey of Older Americans Act Participants (NSOAAP)
Attn: OMB Desk Officer for ACL
The Trevor Project is writing to oppose the Administration for Community Living’s (ACL) continued efforts to remove transgender older adults from the National Survey of Older Americans Act Participants (NSOAAP). In the wake of overwhelming public opposition to ACL’s March 13, 2017 proposal to entirely erase lesbian, gay, bisexual, and transgender (LGBT) older adults from the NSOAAP, we commend ACL on its decision to keep the sexual orientation question on the survey. With no rationale or justification, however, ACL continues to propose eliminating the question on gender identity from the survey. The needs and experiences of all transgender individuals, from young people to our elders must be counted. We write to strongly advocate for ACL to add back in the question on gender identity to this survey.
The more we know, the more we can do to make sure that transgender older adults receive the services they deserve. The NSOAAP survey provides critical data on whether federally funded aging programs like meals on wheels, family caregiver support, adult daycare, and senior centers reach all older adults, including transgender older adults. While ACL’s notice in the Federal Register provides no articulation of, information about, or explanation of ACL’s effort to erase transgender older adults from the NSOAAP, what we do know is that ACL will no longer have data on how the aging network is meeting the needs of this population.
The Trevor Project is the leading national nonprofit organization providing crisis intervention and suicide prevention services to lesbian, gay, bisexual, transgender and questioning/queer (LGBTQ) people. We work to save LGBTQ lives through our accredited free and confidential lifeline; our secure instant messaging services which provide live help and intervention; our social networking community for LGBTQ youth; and our in-school workshops, educational materials, online resources, and advocacy. A San Francisco study has shown that 15% of the LGBTQ elders surveyed had seriously considered suicide within the last year. The study also found that LGBTQ elders had poor physical and mental health. Including gender identity would provide pivotal data that would help guide policies to best serve LGBTQ mental health. The Trevor Project is committed to providing the best crisis intervention services to all LGBTQ people who call us and to meet that goal data collection on the transgender population in federal surveys must continue.
Data, research, and the experience of our colleague organization SAGE (Advocacy and Services for LGBT Elders), its affiliates, and its partners across the country confirm that transgender older adults face a number of barriers to successful aging. While data on transgender older adults is limited, which further makes the case for ACL to continue collecting this information, the data that does exist shows that transgender older adults face higher rates of social isolation and have thinner support networks than their non-transgender peers. The existing research also shows that transgender elders age without a network of welcoming or culturally competent aging, health, and social service providers.
According to Understanding Issues Facing LGBT Older Adults, 25% of transgender older adults report having faced discrimination based on their gender identity, transgender older adults face much higher rates of psychological distress than their non-transgender peers, and nearly 50% live at 200% of the federal poverty line or lower. These challenges are compounded by concerns related to caregiving and by limited access to healthcare. Almost one third of transgender people don’t know who will care for them and approximately two thirds fear their access to healthcare will be limited as they get older. As a result, more than half fear they might be denied medical care as they age. Many transgender elders fear health professionals discovering their transgender status—particularly those whose presentation does not conform with their anatomy. These concerns are often reflected in long-term care settings. In a survey on LGBT older adults living in long-term care facilities, more than 10% of respondents said that they, a client, or loved-one had witnessed staff refusing to call transgender residents by their preferred name or pronoun.
A 2001 U.S. Administration on Aging study found that LGBT older adults are 20% less likely than other older adults to have access to government services such as housing assistance, meal programs, food stamps, and senior centers. In other words, despite their greater need for service providers due to their truncated support networks, transgender older adults lack access to culturally competent care and services. Nonetheless, most State Units on Aging are making no systematic efforts to assess and address the needs of this population. The very age of the 16 year-old ACL study we cite further demonstrates the necessity for ACL to collect updated data on whether the aging network is meeting the needs of this population.
Rather than abandoning the efforts that have been made during the last three years, ACL can increase the quality and utility of the data it collects about transgender older adults by learning from the experience of other federal and state agencies that have successfully implemented procedures to collect gender identity information. To that end, we believe the 2014-2016 NSOAAP’s gender identity question (found under DE1a1. “What do you mean by something else?”) can and should be made significantly shorter and, at the same time, more effective. The Centers for Disease Control and Prevention’s Behavioral Risk Factor Surveillance System (“BRFSS”), which is the largest ongoing health survey system in the world, and its state partners, provide a number of examples of how ACL can successfully identify transgender individuals. The Gender Identity in U.S. Surveillance (GenIUSS) Group provides another, particularly effective, and well-vetted two-step approach to collecting information about gender identity. In short, we encourage ACL to update its approach, rather than abandoning this question, and adopt one of these more effective and efficient means of counting transgender elders.
ACL must continue collecting data on whether the aging network is reaching transgender older adults in order to ensure maximum inclusion of transgender older adults in programs funded under the Older Americans Act (OAA). From State Units on Aging to Area Agencies on Aging, the aging network has asked ACL for more and better data on transgender older adults in the communities it serves. We need more of this data on the experiences and needs of transgender elders in our country—not less of it.
We therefore urge ACL to retain both sexual orientation and gender identity questions in the NSOAAP. Asking a demographic question about gender identity will increase the quality, utility, and clarity of the information collected. We further believe that by continuing to collect this data, and learning more about this population, ACL and the aging network will help more members of our older transgender community to live independently, minimize the burden on the aging network, and ultimately save taxpayer resources by reaching those who are most vulnerable.
CEO & Executive Director
Adelman, M., Alcedo, M et al. (2014).LGBT Aging at the Golden Gate: San Francisco Policy Issues & Recommendations
(pp. 42-43) (United States, City and County of San Francisco, Human Rights Commission). San Francisco, CA: City and County of San Francisco.
 A SAGE report found that: State Plans filed by 29 States make no reference whatsoever to LGBT older adults; an additional 12 State Plans have isolated references to LGBT older adults, but do not address specific actions being taken to reach and target this population; and only nine States, and the District of Columbia, specifically address efforts to reach out and target LGBT older adults.
 The 2013 Massachusetts SOGI module for the BRFSS includes the following question: Some people describe themselves as transgender when they experience a different gender identity from their sex at birth. For example, a person born into a male body, but who feels female or lives as a woman. Do you consider yourself to be transgender? Yes, transgender, male to female; Yes, transgender, female to male; Yes, transgender, gender non-conforming; or No. See Williams Inst., Best Practices for Asking Questions to Identify Transgender and Other Gender Minorities on Population-based Surveys. Available at http://williamsinstitute.law.ucla.edu/wp-content/uploads/geniuss-report-sep-2014.pdf