Report 2022-102 Recommendation 8 Responses

Report 2022-102: California Department of Public Health: It Has Missed Opportunities to Collect and Report Sexual Orientation and Gender Identity Data (Release Date: April 2023)

Recommendation #8 To: Public Health, Department of

To consistently collect accurate SOGI data, Public Health should standardize its definitions and provide guidance on how its forms should ask questions related to sexual orientation and gender identity, guidance on the minimum categories or response options to be collected, and guidelines on how to aggregate and report responses.

Annual Follow-Up Agency Response From October 2024

- The Sexual Orientation and Gender Identity (SOGI) workgroup has drafted updated SOGI data collection recommendations and new SOGI data display recommendations, combined into one document. The document incorporates feedback the SOGI workgroup received from programs across CDPH. We are working with the County Health Executives Association of California (CHEAC) and the California Conference of Local Health Officers' (CCLHO) executive committee on recommendations to gain Local Health Jurisdiction's (LHJ) feedback.

- The Office of Health Equity's (OHE) Guide to Promote Equitable Data Strategy, which CDPH programs is piloting, includes the document. OHE is soliciting feedback on the Guide from LHJs and community groups.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

We look forward to reviewing Public Health's progress toward implementing our recommendations.

1-Year Agency Response

- The SOGI workgroup has received feedback from Local Health Jurisdictions (LHJs) and community organizations on our recommended best practices for collecting SOGI data, including definitions, wording, and format of SOGI data questions and response fields. The SOGI workgroup is currently drafting an updated set of data collection recommendations, incorporating feedback and additional research on best practices for collecting SOGI data.

- Center for Health Statistics and Informatics (CHSI) staff have drafted recommendations addressing the major issues that affect the display of SOGI data. This includes providing privacy protection of small cell sizes and sources for denominator data. These recommendations are currently in the process of being reviewed by the SOGI workgroup for additional considerations.

California State Auditor's Assessment of 1-Year Status: Pending

We look forward to reviewing the department's progress toward implementing our recommendation.

6-Month Agency Response

- The SOGI workgroup created the standardized definition, wording, and format of SOGI data questions and response fields. We are collecting stakeholder feedback and Public Health will post the feedback on its website once it is reviewed and considered.

- The SOGI data display standards are still in discussion. Staff are developing recommendations addressing the major issues that affect the display of SOGI data, including privacy protection of small cell sizes and sources of SOGI denominator data.

- The last form has been updated to meet SOGI standards. See "Form_The California WISEWOMAN Program.pdf"

- Public Health is considering a data collection/forms workgroup to review all data collection forms utilized within the department and streamline data collection practices, including a periodic review of whether forms are required to collect SOGI data, assessment of SOGI data collection processes, and review of program reasons for not collecting SOGI data in accordance with departmental standards, once those standards are distributed.

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

- Public Health is continuing to support the 2022 SOGI Workgroup on the data collection recommendations, which provide updated guidance on SOGI question wording and response options. These recommendations are with the Director's Office for review and approval.

- Planning is underway on reconvening the SOGI Workgroup to address SOGI data display standards. Issuance of data display standard recommendations will complete the goals of this workgroup.

- Of the seven forms identified as non-compliant in the audit report, further investigation has revealed that three of these forms were one-time use only and no longer relevant to the report. Two forms will be compliant by July 1, 2023 and the other form will be compliant by September 30, 2023. Public Health is in conversation with the program responsible for the one remaining form to develop a workplan to make the form compliant.

- Public Health will direct all centers to form data collection/forms workgroups to review all data collection forms utilized within the centers and streamline data collection practices, including a periodic review whether forms are required to collect SOGI data, assessment of SOGI data collection processes, and review of branches' reasons for not collecting SOGI data, in accordance with Departmental standards.

California State Auditor's Assessment of 60-Day Status: Pending

We look forward to reviewing Public Health's progress towards implementing this recommendation.

All Recommendations in 2022-102

Agency responses received are posted verbatim.