Transgender older adults must be reinstated to key federal aging survey

Each year, the Administration for Community Living (ACL) of the U.S. Department of Health and Human Services (HHS) conducts the National Survey of Older Americans Act Participants (NSOAAP). This survey provides critical information on federally funded aging programs created and authorized by the Older Americans Act (OAA), including transportation services, caregiver support, adult day care, senior centers, health and wellness programs, legal-assistance services, longterm-care ombudsman services to residents of nursing homes and elder-abuse protection.

The Administration on Aging (AoA), the agency within HHS responsible for carrying out the provisions of the OAA, then evaluates the survey results to determine the efficacy of these programs and whether they are reaching all older adults, including LGBTQ elders. 

Thanks to considerable advocacy by LGBTQ groups, the survey has included questions on both sexual orientation and gender identity since 2014. The inclusion of these questions in the survey was the culmination of extensive work encouraging the federal government to recognize the importance of data collection to better understand the needs of the growing population of LGBTQ elders.

However, earlier this year, the ACL, which oversees the AoA within HHS, eliminated questions inviting survey participants to identify as LGBTQ. ACL offered no grounds for the decision and, in fact, said there were “no changes of a currently approved collection” in its draft of the survey published in March, despite the absence of the questions pertaining to sexual orientation and gender identity.

In response, advocates for LGBTQ older adults organized a nationwide effort to oppose the proposed elimination of LGBTQ elders from the survey. Thousands of people around the country sent comments and feedback voicing their opposition. In June, as a direct result of the overwhelmingly critical reaction, the ACL announced that it would restore the question about sexual orientation.

This reversal represents a significant victory and demonstrates that the ACL heard the message from LGBTQ older adults, advocates and elected officials. That said, the ACL’s response was incomplete, as it plans to continue with the removal of the question on gender identity. 

ACL’s refusal to reinstate the question pertaining to gender identity is unacceptable. If it does not restore this query, transgender older adults will not be counted and information about how they are being served by the OAA will not be collected. Such an exclusion would not only be egregious, in that transgender adults would be the sole demographic cut from the survey, but also incompatible with the federal government’s responsibility under the OAA to serve all elders.

Although all older people face many challenges inherent in the aging process, transgender individuals confront serious, additional barriers that other older adults do not, mostly as a result of past and present discrimination. Additionally, most aging-service providers are ill-equipped to provide competent and nondiscriminatory services to transgender populations. Consequently, collecting data on the experiences of transgender elders is absolutely critical to understanding their unique needs and improving access to the services for which they are eligible under the OAA. 

It is also critical to ensuring the accuracy and success of the survey, which is intended to evaluate the effectiveness of federal programs serving older adults. If older transgender adults are not counted, it is not possible to fully evaluate the efficacy of these programs. Erasing transgender older adults from the NSOAAP subverts the objective of both the OAA and the survey.

HHS has opened a second period of public comment on the NSOAAP. You can help advocate for transgender older adults by submitting comments about the importance of retaining the survey question on gender identity by July 24. 

You may submit written comments by fax to 202-395-5806 or by email to OIRA_ [email protected], using the below information: 
Attn: OMB Desk Officer for ACL
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)
Please tell HHS to:
  1. Restore the gender identity question to the National Survey of Older Americans Act Participants.
  2. Continue efforts to make elder services more culturally competent to serve LGBT people.
  3. Analyze and publish the results of these surveys on a regular basis.

Those seeking further information can contact Heather Menne at 202-795-7733 or [email protected]

You can also sign the online petition created by Services & Advocacy for GLBT Elders (, which takes less than one minute to complete.

Now more than ever, we must refuse to stay silent or to be invisible. We must show our strength in numbers and our unity against the erasure of transgender older adults. If the ACL reacted to the message before, hopefully they will hear it again when contacted more specifically about gender identity.

Andrea C. Anastasi is an attorney, writer and advocate committed to effecting positive change, spreading awareness and connecting people to help the arc of the moral universe bend toward justice. She uses her expertise to support public-interest issues and collaborates with socially conscious organizations including the LGBT Elder Initiative, where she serves as a member of the Advocacy Committee. She believes that kindness is contagious and encourages anyone who has read this far to spread the love.