At the end of 2025, just before the holidays, the federal government released a flurry of anti-transgender proposals. One set of proposals from the Centers for Medicare and Medicaid Services (CMS) would prohibit healthcare professionals nationwide from receiving any Medicare or Medicaid funding if they provide evidence-based, medically necessary health care services to transgender minors related to their gender identity, like puberty blockers and hormone replacement therapy (HRT).
This care for youth is already banned in Texas through SB 14 (Campbell) which took effect in 2023. Since then families of transgender youth have been forced to leave the state to keep their adolescents safe. Doctors who previously provided care have faced their own “agonizing moral dilemma, stay in Texas and deny care to patients, knowing it will jeopardize their health while breaching professional ethics; or begin the strenuous process of moving their medical license, practice and family elsewhere,” according to Alex Sheldon, executive director of GLMA (previously known as the Gay & Lesbian Medical Association).
Categorical bans on health care for transgender youth have also led to a chilling effect for adult health care. As essential health care is politicized and providers leave the state, there are fewer resources to go around for adults, even though care is still legal.
The proposed federal rules from CMS threaten to stretch these resources even further by drastically reducing the number of out-of-state providers that can afford to provide care.
Importantly, Resource Center has continued to provide transgender adults (18+) with comprehensive care including culturally competent primary doctors, HRT, and mental health care.
Medically necessary care for transgender youth
Health care for transgender youth is evidence-based, medically necessary care comprised of decades of research. Every major U.S. medical association supports young people’s access to age-appropriate gender affirming health care including the American Medical Association, the American Academy of Pediatrics, the American Psychiatric Association, and the Endocrine Society. Care is safe, effective, and has been found to reduce negative mental health outcomes and improve overall health and quality of life.
Bans on health care for transgender youth are not about efficacy or safety of the actual care, they’re about denying transgender people the right to make their own individualized health care decisions with their doctors that will improve their lives.
The proposed rule demonstrates this clearly by combining several different types of health care for transgender youth under the umbrella of “sex-rejecting procedures,” a phrase coined by the conservative Washington D.C. think tank Ethics and Public Policy Center. The emphasis is not on the care itself, but on denying care related to transgender people’s experiences of their own gender identity.
What’s the impact?
These rules go beyond the current politization of health care for transgender people. They push the limits of how far the federal government can control what treatment doctors can or cannot provide their patients.
As a federal agency, CMS is not allowed to “exercise any supervision or control over the practice of medicine.1” By threatening eligibility for Medicare and Medicaid programs, the Trump Administration has put health care providers in an impossible situation. Unless providers cruelly end evidence-based, medically necessary care for an entire demographic group (transgender youth), they will lose the funding they rely on to care for everyone. According to the Kaiser Family Foundation (KFF), Medicare and Medicaid account for nearly 45% of spending on hospital care.
If the proposed rule is successful, CMS will have a blueprint on how to more broadly control what doctors can and cannot do through threatening their access to Medicare and Medicaid funding.
What can you do?
When federal agencies propose new rules, they’re required to include a public comment period to collect feedback on how the new rules would impact people’s day-to-day lives. The final version of the rule becomes a federal regulation.
The agency has to review and consider public comments before they finalize the rule. If the agency decides to finalize the rule, public comments can support legal challenges since they document the harm in how the rule would be applied.
Anyone can comment. It doesn’t have to be long (even just a paragraph is enough) and it’s best to use your own words. Some topics you can think about are:
- How age-appropriate care for transgender youth has benefitted you or someone in your life (if they received care before it was banned or if they’re receiving care outside of Texas).
- How the denial of age-appropriate care for transgender youth has harmed you or someone in your life.
- How federal agencies should not be in the business of manipulating funding access to dictate what care is available to patients and their doctors.
The deadline for commenting is February 17th.
Note: Comments on the portal are publicly available, and you are allowed to comment anonymously. Do not share any private identifying information like your physical address, email address, phone number, healthcare information, provider names or details. Broad statements of your experiences are enough.
We’ve made it as easy as possible to submit your comment you don’t even need to navigate the Federal Register yourself. We’ve partnered with CenterLink and HRC to set up a page that will automatically submit your comment on your behalf.
