Public Comment

Data Collection on COVID-19: Public Comment

March 2021

Federal, state, and local agencies have implemented data collection and monitoring systems to gather information about individuals who are diagnosed with COVID-19. However, these systems do not currently collect or report data on the sexual orientation or gender identity of those impacted.



These comments address barriers to the collection, analysis, and regular public reporting of detailed disaggregated demographic data on individuals with COVID-19.


Williams Institute research has found that many LGBT people have underlying conditions that make them particularly vulnerable to serious illness related to COVID-19 infection. Inclusion of sexual orientation and gender identity measures in COVID-19 monitoring systems is necessary to fully understand the impact of the pandemic on the LGBT community.


The Williams Institute has urged federal and state governments to collect and timely report data on patients’ sexual orientation and gender identity, along with other demographic characteristics, including race, ethnicity, sex, primary language, disability status, and socioeconomic status. These data would help the public health system respond to the crisis and would help policymakers address the needs of and distribute resources to those who are most vulnerable.

Download the US Department of Commerce Comment (July 2021)

Download the US Department of Commerce Comment (Feb 2021)

Download the HHS letter

Download the State of California letter

Data Collection on COVID-19: Public Comment