The Government Doesn’t Seem to Care About Transgender Seniors, but You Can Make It

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June 29, 2017

On March 13, 2017, the Department of Health and Human Services (HHS) notified the public that it was making changes to its annual consumer assessment survey for participants in programs funded under the Older Americans Act.

The survey’s purpose is to create a portrait of older adults who are receiving federally funded aging services -- such as “meals on wheels,” transportation, delivery, senior centers and caregiver support -- and to assess how those programs are working for them. The information gathered is used to inform future program development and to support budget requests.

What HHS failed to mention in its notice, however, was that key demographic questions about sexual orientation and gender identity had been removed.

In response to this shameless erasure, the agency was flooded with comments from individual seniors, advocacy organizations, service providers and aging agencies that urged it to reinstate the questions.

Thanks to the thousands of comments that were submitted, HHS announced last week that it would be reinstating the question about sexual orientation.

But the agency has still failed to include the question regarding gender identity.

While we celebrate the grassroots victory that led to the reinstatement of the question regarding sexual orientation, HHS should never have erased it in the first place. And we must not let it erase transgender seniors from the survey altogether.

Transgender elders rely heavily on aging services.

Why? Because they experience more social isolation that non-transgender seniors, and are more likely to be economically dependent on aging services because they have experienced a lifetime of financial instability as a result of employment discrimination. They are also more dependent on aging services because they have experienced long-term negative health care outcomes as a result of health care discrimination.

Fact: If the voices of transgender seniors are absent in the process of shaping federally funded aging programs, those seniors will be reulctant to access aging services they desperately need, having gotten the message that those programs are not meant for them.

Failing to gather information about whether these programs are meeting the needs of transgender elders will result in ill-informed decisions about how to use public resources to meet the needs of elders across the country.

And the potential ACA repeal factors in here too.

The kinds of federally funded aging support services transgender seniors – and all older people – rely upon in order to age successfully in their homes will become even more critical if the Affordable Care Act (ACA) is repealed. The increase in health care costs that will flow to seniors under the most recent version of the repeal legislation, and the loss of substantial funding for nursing homes as a result of the cuts to the Medicaid program, will result in financial hardship and fewer health services for older adults.

All that combined with the prevalence of discrimination transgender seniors experience in health care settings will increase these seniors’ need for the kinds of home and community-based support services funded by under the Older Americans Act.

But without data about how to provide these essential services in a culturally competent and targeted way, transgender seniors will fall through the cracks.

This erasure is particularly troubling in light of the history, over too many generations, of the transgender community’s invisibility to government and researchers.

For all of us, high quality, accurate data that captures the diversity of our community is essential to our advocacy efforts to ensure that LGBTQ people “count,” both in a literal sense and in terms of policy priorities.

So, what can you do to help?

This: Show up for transgender seniors by submitting a comment by email to HHS and urging it to reinstate the question regarding gender identity.

Below is a sample comment that we encourage you to adapt and personalize. You can submit written comments by email to, Attn: OMB Desk Officer for ACL or by fax at 202-395-5806. The comment period ends on July 24, 2017.

Sample Comments

ATTN: OMB Desk Officer for ACL
U.S. Department of Health and Human Services
Administration for Community Living
330 C St. SW
Washington, DC 20201

To whom it may concern,

Thank you for the opportunity to provide comment in response to the Notice of Proposed Collection of Information published in the Federal Register on June 22, 2017, at 82 FR 28491-92. I write in opposition to the most recent proposed form of the 2017 National Survey of Older Americans Act Participants (NSOAAP), noticed as a “proposed collection of certain information” on June 22, 2017. 

While I appreciate that the question regarding sexual orientation was reinstated following a previous notice and comment period, the proposed survey continues to eliminate a previously used demographic question relating to the participant’s gender identity.  I object to the removal and failure to reinstate this question and urge ACL to include the question they have used for the last three years that recognizes the unique struggles transgender elders face in accessing necessary services.

Aging services such as meal home delivery, transportation, caregiver support and senior centers are lifesaving resources. And transgender older adults rely upon these services because they experience more social isolation than non-transgender people. LGBT older adults are twice as likely to live alone and more than four times as likely to have no children than non-LGBT people. In addition, transgender seniors rely heavily upon aging services because they have experienced a lifetime of financial instability as a result of employment discrimination and are more likely to have experienced long-term negative health care outcomes as a result of health care discrimination. Finally, transgender elders lack access to culturally competent aging programs and services. If they are unable to help shape the performance and development of aging programs, they will avoid services they desperately need, exacerbating the already existing economic and social barriers affecting their lives.  

There is a dire need for more information as to whether OAA funded programs are meeting the needs of their transgender program participants.  To erase transgender demographic questions from the survey is to pretend that the needs of transgender older Americans do not exist.  Indeed, it is to pretend that transgender older Americans themselves do not exist.

We strongly encourage ACL to reinstate the deleted question regarding gender identity.  ACL must commit to serving all elders, and that begins with a comprehensive survey that reveals whether OAA programs are reaching older transgender Americans in need.