Report 2022-102 Recommendation 9 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 #9 To: Public Health, Department of

To consistently collect accurate SOGI data, Public Health should complete and implement the goals of its 2022 SOGI workgroup.

Annual Follow-Up Agency Response From April 2026

Public Health fully implemented Recommendation #9 by executing the objectives of the 2022 SOGI Workgroup. The Workgroup's objectives were to:

1. Develop best-practice guidance and a data dictionary for SOGI data collection.

2. Document best practices for SOGI data display.

3. Create reference standards for external partners, including LHJs.

Public Health accomplished the objectives through the development, approval, and release of the Best Practices Guidance for Sexual Orientation and Gender Identity (SOGI) Data Collection and Display. The guidance underwent a rigorous, multi-stage development process grounded in national best practices and informed by extensive feedback from LGBTQIA+ community members, Public Health's staff, LHJs, the CHEAC, the CCLHO, the Public Health Data Stewards Committee, the Public Health Data Governance Council, and the California Conference of Local Health Data Managers and Epidemiologists (CCLHDME).

Public Health disseminated the final guidance to all Public Health CDOs, posted on the internal Data Hub, and published it on Public Health's website for external stakeholder use. Public Health also announced its release through multiple stakeholder channels, including the Office of Health Equity's (OHE) monthly equity technical assistance calls with LHJs, and communications to CHEAC, CCLHO, and CCLHDME.

These actions fully satisfy the objectives of the 2022 SOGI Workgroup and support consistent, accurate SOGI data practices across Public Health and its partners.

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

Annual Follow-Up Agency Response From October 2024

- The 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 Public Health. We are working with CHEAC and CCLHO executive committee on recommendations to gain LHJ's 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 LHJs and community organizations on our recommended best practices for collecting SOGI data. The SOGI workgroup is presently reviewing and considering all feedback received. 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.

- CHSI Staff have drafted recommendations addressing the major issues that affect the display of SOGI data, including the need for 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.

- CHSI has recently dedicated a full-time project manager to oversee and maintain the consistent and accurate collection and display of SOGI demographic data across 21 Public Health centers and programs.

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. See "CDPH Best Practice Recommendations for Collecting SOGI.docx"

- 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.

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.