Public Comment

National Association of Insurance Commissioners: Public Comment

August 2021

In July 2021, the National Association of Insurance Commissioners requested feedback on its Principles for Data Collection, which intended to enhance data collection and reporting on insured people.

  • Luis A. Vasquez
    Staff Attorney, Former
Public Comment


The National Association of Insurance Commissioners (NAIC) is a non-governmental regulatory organization created and governed by chief insurance regulators in the U.S. The NAIC’s Special Committee on Race and Insurance drafted its Principles of Data Collection to identify sociodemographic factors of insured people, including sexual orientation and gender identity, which it recommends insurance companies collect.


LGBT people experience various mental and physical health disparities compared to their non-LGBT peers as a result of experiencing stigma. In addition, our research shows that many LGBT people report facing challenges in accessing health care, particularly among LGBT people of color.


The comment commends the NAIC’s recommendation that insurance companies collect information on people’s sexual orientation and gender identity (SOGI). It explains that collecting data on the demographics and experiences of LGBT people helps medical providers provide the highest quality care to LGBT patients. Having reliable SOGI data also allows researchers and policymakers to develop statutory, regulatory, and other interventions that properly address disparities in health care access and outcomes between LGBT and non-LGBT people.

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National Association of Insurance Commissioners: Public Comment