Dear Ms. Dumas,

We write in response to the Notice titled “American Community Survey Methods Panel: 2024 Sexual Orientation and Gender Identity Test,” published in the Federal Register on September 19, 2023 requesting comments on the Census Bureau’s proposed plan to conduct the 2024 American Community Survey (ACS) Sexual Orientation and Gender Identity (SOGI) Test, a test that advances the research about how SOGI questions would perform on the ACS. We applaud the Census Bureau for continuing to improve responsible government data collection on LGBTQI+ communities by testing questions to gather SOGI data on the ACS.

While we do not have the expertise to address specific terminology, methodologies, and other technical issues in the Federal Register Notice, we strongly support this test and the thoughtful, deliberative, and scientific process to include SOGI measures on the ACS. We also urge the Census Bureau to conduct additional testing of these measures beyond English and Spanish, to support development of accurate supplementary materials for the ACS. Finally, we encourage the Census Bureau to proceed with submitting the information collection request to the Office of Management and Budget and hope that OMB will expeditiously approve the request.

The collection of SOGI data through Census Bureau programs, including the ACS, is critical to the work of foundations and nonprofits. Improved ACS data on sexual orientation, gender identity, and variations in sex characteristics would allow us to better understand the experiences and needs of diverse LGBTQI+ communities including people of color, those with disabilities, and those living in rural areas; better direct funding to programs designed to serve these populations; and more accurately evaluate the impact of philanthropic funding.