GSL Pens Public Comment on Federal Evidence Agenda for LGBTQI+ Equity

By Helen Zhao and Sarah S. Richardson

This September, members of the GenderSci Lab collectively drafted a letter to the subcommittee tasked with developing and releasing a Federal Evidence Agenda on LGBTQI+ Equity. Our letter, submitted two weeks ago, responds to a request for public input on the call for “inclusive and responsible” federal data collection practices on “disparities that LGBTQI+ individuals, families, and households face, while safeguarding privacy, security, and civil rights” included in President Biden’s recent Executive Order 14075 on Advancing Equality for Lesbian, Gay, Bisexual, Transgender, Queer, and Intersex Individuals.

The federal committee will be responsible for outlining broad principles and policy directions for federal data collection practices on LGBTQI+ communities. Our public comment is informed by our deep experience working with the operationalization of sex, gender, and sexuality categories across diverse fields of biological and medical research. During the collaborative writing of this piece, a common theme emerged. Lab members agreed, as we write in the letter, that “more data is not always better.” We emphasize that, “To fully realize the benefits of scaling up data collection on interlocking oppressions faced by sexual and gender minorities will require anticipating and working to ameliorate potential risks and pitfalls” and supporting “rigorous social science and humanities research on the conceptual foundations of sexual and gender categories and on the social and cultural contexts in which data is collected.”

“To fully realize the benefits of scaling up data collection on interlocking oppressions faced by sexual and gender minorities will require anticipating and working to ameliorate potential risks and pitfalls.”

You can see the full text of our submitted letter below and download it as a PDF here. In our letter, we recommend that the following principles guide changes to federal data collection practices:

  • High priority on trust, privacy, and consent.  

  • Clear understanding that gender inclusion is not the same as gender analysis.

  • LGBTQI+ data should not be linked to biological materials or samples without special review and oversight.

  • Actively counter essentialist and binary categories.

We also offer policy recommendations for data collection on LGBTQI+ individuals by federal agencies, modeled after our lab’s own rigorous social science and humanities research on the conceptual foundations of sexual and gender categories, and our commitment to appropriately contextualizing the presentation and public translation of data on biomedical outcome disparities.

We welcome your comments and questions about the content of the letter. To contact the lab, please email genderscilab@gmail.com.

Suggested Citation

Zhao, H. and Richardson, S.S. “GSL Pens Public Comment on Federal Evidence Agenda for LGBTQI+ Equity.” GenderSci Lab Blog. 2022 Oct. 17. genderscilab.org/blog/public-comment-on-federal-evidence-agenda-lgbti-equity

Statement of Intellectual Labor:

Kelsey Ichikawa, Annika Gompers, and Marina DiMarco developed and edited this blog in collaboration with Helen Zhao and Sarah Richardson, who authored the letter. Jeff Lockhart, Kai Jillson, Kai DeJesus, and Meg Perret offered suggested revisions to the letter. Lab-wide discussions contributed to ideas expressed in the letter.

Image Thumbnail Credit

"SCOTUS APRIL 2015 LGBTQ 54663" by tedeytan is licensed under CC BY-SA 2.0.

Sarah Richardson