The Trump administration is proposing another update to its national aging survey, the National Survey of Older Americans Act Participants (NSOAAP), and it’s once again leaving transgender older adults out in the cold.

This survey helps determine whether the most vulnerable older adults in our country are getting the services and supports they need under the Older Americans Act, which funds programs and services like Meals on Wheels and senior centers.

While the proposed survey provides an opportunity for older adults to identify their sexual orientation, it does not provide them an opportunity to identify their gender identity.

The proposal is open for public comment through Monday, November 27, 2017 at midnight.

The text below can be used in the body of a letter that is then sent to the Administration for Community Living (ACL) via e-mail (heather.menne@acl.hhs.gov) by the Monday November 27th deadline. This template can be customized and personalized to better speak to why you care about the issue.

 

November 27, 2017

VIA E-MAIL: heather.menne@acl.hhs.gov

RE: Agency Information Collection Activities; Public Comment Request; Redesign of Existing Data Collection; National Survey of Older Americans Act Participants

 

I am writing to applaud the Administration for Community Living (ACL) for keeping a sexual orientation demographic question in the latest iteration of the National Survey of Older Americans Act Participants (NSOAAP), announced September 26, 2017.   We are disappointed, however, that ACL is continuing to deny the opportunity for transgender older adults to identify themselves in the survey.

Earlier this year, thousands of people and organizations wrote to oppose ACL’s March 13, 2017, proposal to entirely erase lesbian, gay, bisexual, and transgender (LGBT) older adults from the NSOAAP.  When the survey went up to the Office of Management and Budget (OMB) for review, many commended ACL’s decision to keep a sexual orientation question in the survey, but condemned ACL’s decision to omit a question from the survey designed to identify transgender respondents.

ACL has now announced a new, longitudinal NSOAAP, which is a powerful tool to help address changing needs of populations over time.  While we once again commend ACL on its decision to collect data on sexual orientation, we once again condemn ACL’s decision to not collect data that will allow ACL and researchers to identify and study the transgender population in this survey.  All of our elders, including our transgender elders, must be counted. We refuse to let transgender older adults, or any of the elders who are part of our community, be invisible.

The more we know, the more we can do to make sure that transgender older adults receive the services they deserve. The NSOAAP 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 decision to omit a transgender-inclusive gender identity question(s) from the NSOAAP, what we do know is that if this decision stands, ACL will not have important data on how the aging network is meeting the needs of transgender elders.

ACL’s latest proposal is fundamentally at odds with our vision of recognizing the diversity of America’s older population and working to ensure that no older person is a victim of discrimination. In recent years, ACL has made significant progress in addressing the needs of transgender older adults. ACL’s decision to not measure gender identity on the NSOAAP, however, represents a lost opportunity to support the progress we have made in recent years and counters the call for more, not less, data from the aging network on the population it serves.

Data, research, and the experience of SAGE, 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 collecting this information, the data that do exist prove that transgender older adults face higher rates of social isolation and have thinner support networks than their cis-gender 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 cis-gender 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.

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.

ACL can increase the quality and utility of the data it collects about transgender older adults by following the lead of other federal and state surveys that have successfully implemented procedures to identify transgender respondents, such as the National Crime Victimization Survey, the Behavioral Risk Factor Surveillance System (“BRFSS”), and the California Health Interview Survey.  To that end, we believe a concise gender identity question or questions can be included in this newest version of the NSOAAP. The widely-cited best practices guidelines, edited by the Williams Institute, for measuring gender identity on population surveys, identifies an effective and well-vetted two-step approach to collecting information about gender identity. In short, we encourage ACL to adopt a measure of gender identity on the NSOAAP.

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 include 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.

Sincerely,

Your name here