My VA gender marker change didn’t quite go as plannedTrans Progressive Thursday, July 21st, 2011
Commentary: Trans Progressive
“One can change one’s (Veterans Affairs) record to reflect one’s gender without genital reconstruction surgery.”
This was from the National Center For Transgender Equality’s (NCTE’s) talking points regarding a significant change to Veterans Affairs (VA) policies for transgender veterans. This change of policy on gender markers was clearly intended by the senior leadership of the VA when they put out the new policy document in mid-June, but how the policy is apparently being implemented is different from the initial intent.
In mid-June, I applied at the San Diego Veterans Affairs Health Care Center to have my gender marker changed in my Veterans Affairs (VA) records. This was after the VA announcement that a new Veterans Health Care Administration (VHA) directive (VHA Directive 2011-024) had been released, entitled Providing Health Care For Transgender And Intersex Veterans.
In the new VHA Directive 2011-024, entitled Providing Health Care For Transgender And Intersex Veterans, is the document that the VA announced in June. Paragraph 4. (1)(b) of the directive states the following:
“The documented sex in the Computerized Patient Record System (CPRS) should be consistent with the patient’s self-identified gender. In order to modify administrative data (e.g., name and sex) in CPRS, patients must provide official documentation as per current VHA policies on Identity Authentication for Health Care Services and Data Quality Requirements for Identity Management and Master Patient Index Functions.”
My first request was rejected. I received a letter, dated June 24, 2011, from the San Diego Veterans Affairs Health Care Center’s acting director stating as much.
That second referenced document is apparently the key document for the requirements for gender marker change – VHA Directive 2006-036, Data Quality Requirements For Identity Management And Master Patient Index Functions. It states the following in Attachment A, paragraph 4:
“GENDER: Male or Female must be entered. In case of gender reassignment, legal documentation (amended birth certificate, court documents, etc.) must be required as proof of a legal gender change.”
I provided a copy of my California Driver License to the VA, which has an F as the gender marker with my initial filing. That filing was rejected in a letter to me from the VA.
When I talked on Tuesday, July 12, 2011 to the San Diego VA Medical Center’s privacy officer about the filing, he told me he spoke to the attorneys and staffers at the Identity Management Data Quality (IMDQ) team in Washington, D.C.
In documentation from that group sent to the privacy officer that I wasn’t allowed to see, the conclusion was that my DL with the F as a gender marker was inadequate documentation. They apparently construed the paragraph from VHA Directive 2006-036 very narrowly, believing a surgery letter or an updated birth certificate was the only acceptable documentation.
It should be noted that with some internet searching I did find the current home page for the IMDQ team. I found out that in 2009 the name of the IMDQ team changed to Healthcare Identity Management (HC IdM). Apparently, the key document for HC IdM is the Master Patient Index/Patient Demographics (MPI/PD) Vista; Programmer Manual (Version 1.0) – the relevant thing here is mostly the name change of the team from IMDQ to HC IdM – why the privacy officer didn’t mention the team name change, I don’t know. That bit of information seems pretty important though.
The Palm Center and TAVA did heavy lifting in creating a study that highlighted the problems of disabled veterans. NCTE did the heavy lifting of working with the Obama Administration in addressing the highlighted problems in creating a new policy document.
As a transgender veteran who’s worked with TAVA and the NCTE, I’ve had the pleasure of doing the much lighter, but equally necessary, lift of testing the policy to make sure that the created policy is implemented as advertized. When I tested the new passport policy, the policy worked as advertized; the VA plan hasn’t worked as advertized as yet.
From here we work to have the lower level management at the VA get in step with what the upper level management meant to accomplish. Accomplishing steps such as this is how community activists work together to accomplish our community goals.
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