Protect Transgender Youth

Urgent Action To Support Federal Funding For Gender-Affirming Healthcare For Minors

In a pair of proposed rules, the current administration seeks to prohibit federal funding under Medicare and Medicaid (for hospitals) and Medicaid and CHIP (for other healthcare providers) for what it calls “sex-rejecting procedures” for children under the age of 18 (under 19 for CHIP payments). The proposed rules would deprive children who qualify for public benefits of the gender-affirming healthcare they and their doctors decide is appropriate. In addition, the proposed rules would defund medical care solely on the basis of recipients’ age and the type of care they seek, a dangerous and cruel precedent for holding children, and eventually any age group, hostage to political priorities.

 

February 17, 2026, at 5:00 p.m. EDT is the deadline to submit comments opposing proposed new regulations that would prohibit the use of Medicare, Medicaid, and Children’s Health Insurance Program (CHIP) funds to pay for gender-affirming health care for minors.

 

 

CALL TO ACTION:  Submit comments opposing the proposed rules

·       Draft your Comment. You can use a nearly identical letter (except for the first paragraph) for both rules. Below is a template for each of the two proposed rules.

 

·       For the Proposed Rule Barring Use of Medicaid/CHIP Funds for Gender-Affirming Healthcare for Minors, submit your comment at: https://www.federalregister.gov/documents/2025/12/19/2025-23464/medicaid-program-prohibition-on-federal-medicaid-and-childrens-health-insurance-program-funding-for

·       For the Proposed Rule Prohibiting Funding to Medicare/Medicaid Hospitals for Gender-Affirming Healthcare for Minors, submit your comment at:

https://www.federalregister.gov/documents/2025/12/19/2025-23465/medicare-and-medicaid-programs-hospital-condition-of-participation-prohibiting-sex-rejecting

 

·       When you open the Federal Register site linked above:

o   Scroll down the left margin to “Public Comments”

o   Click where it says “Submit a public comment”

o   Either cut and paste your comment letter under “Comment” or attach it as a file in the section for uploads.

  

Templates for Comment Letters

Text in italics is provided for guidance only; non-italicized text can be copied directly.

 

1.     Comment on Proposed Prohibition Medicaid and CHIP Funds for Gender-Affirming Care for Minors

 To Whom It May Concern:

 My name is [first and last name] and I live in [city and zip code]. I am writing in opposition to 42 CFR Parts 441 and 457, CMS-2451-P, RIN 0938-AV73, barring hospitals from receiving Medicaid and Children’s Health Insurance Fund (CHIP) funding if they provide gender-affirming care to individuals under 18 (or under 19 for CHIP).

 Personal Experience with Gender-Affirming Medical Care for Minors     

As a guideline, use one of the following four paragraphs. The more details you include, the better. This will help readers understand your position and empathize with you. Most importantly, speak from the heart.

First, describe yourself and your relation to the issue of gender-affirming medical care.

Example 1:

I am a 30-year-old cashier working full-time for a local grocery chain. I am also transgender. I identify as trans-female. I was six years old when I realized the gender I was assigned is not my own. I began my medical transition when I was 18 years old. The state I lived in at the time did not ban gender-affirming care for minors. Growing up feeling like a girl when everyone called me a boy was hard because . . . Becoming trans-female changed my life by . . .

Example 2:

I am a retired carpenter. My godson is transgender and identifies as trans-male. He began to question his gender out loud when he was in high school. Frankly, his parents and I were not surprised. They supported his decision to begin hormone treatments when he was 17 years old as part of his gender-affirming transition. At the time, the state my godson lived in did not ban gender-affirming care for minors. He is now 25 years old and a licensed electrician with a good job and a supportive girlfriend.

Example 3:

I teach eleventh grade in a public high school in Minnesota. Over the years, I have taught three teenagers who later became transgender. I have witnessed how their struggle with their gender consumed their emotional energy and made it difficult for them to focus on learning.

Example 4:

I am morally injured by the proposed rules. Discriminating against any group of people by depriving them of the medical care they and their doctors decide is appropriate for a patient injures the moral fabric of our community.

Second, describe the challenges you or someone you know has encountered when trying to obtain gender-affirming care. If you don’t know anyone personally who received this care, you can speak about these challenges based on your general knowledge. Factors to consider:

·        Was money an issue in getting the medical gender-affirming care? If so:

o   Why was money an issue? (e.g., lack of insurance coverage?)

o   Did affording the medical care depend on getting public benefits?

o   Did anyone make financial sacrifices to help pay for the care?

o   How was the care ultimately paid for?

 

·        What other difficulties were faced in getting gender-affirming medical care? Were any of these issues of concern:

o   Age?

o   The availability of gender-affirming medical expertise?

o   Laws  banning gender-affirming medical care ?

 

·        How did those difficulties impact the affected person’s:

o   Ability to work

o   Financial income

o   Ability to support (including financially) family members, e.g., parents, siblings, children

o   Mental health

o   Physical health

o   Civil rights

 

·        If you did not receive or do not know anyone who has received gender-affirming medical care, how has the unavailability of funding for gender-affirming medical care negatively impacted:

o   Your classroom?

o   Your business?

o   Your medical practice?

o   Your compliance with local and state laws?

o   Civil rights of you and others?

 

Third, if you or those you know have received gender-affirming medical care, what has been the positive impact? Factors to consider:

·        Ability to work

·        Financial income

·        Ability to support (including financially) family members, e.g., parents, siblings, children

·        Mental health

·        Physical health

·        Civil rights

 

Finally, if you are transgender, how you would feel if you lost your current hormone therapy or other medical support?

 

Benefits of Public Funding for Gender-Affirming Medical Care for Minors

I oppose the proposed rules because I want all children to become productive citizens. For that to happen, we have to make sure every child has the physical and mental medical care their doctors prescribe based on medical, scientific research and their doctors’ professional diagnoses. These decisions must be made between professional providers and individual families, not government entities. Every major medical association and leading world health authority supports gender-affirming health care for transgender youth, including the American Academy of Pediatrics, see www.aap.org/en/news-room/aap-voices/why-we-stand-up-for-transgender-children-and-teens, and the American Medical Association, see www.ama-assn.org/press-center/ama-press-releases/ama-states-stop-interfering-health-care-transgender-children. A list of the other health care organizations in support of this care is found at glaad.org/medical-association-statements-supporting-trans-youth-healthcare-and-against-discriminatory.

 

Injuries in the Absence of Federal Funding for Gender-Affirming Medical Care for Minors

 The proposed rule seeks to defund medical care solely on the basis of recipients’ age and the type of care they seek. If our government goes down this path, we could just as easily end up defunding care for treating measles in unvaccinated youth because a future administration wants to penalize anti-vaxxers. Holding children hostage to shifting political priorities is cruel, no matter who’s in charge.

 Without Medicare, Medicaid, and CHIP funding for gender-affirming medical care for minors, we risk depriving children who need that care the safest, most efficient path to their authentic sense of self and to their ability to thrive as adults and contribute to our society. As noted in the December 23, 2025, Journal of Pediatrics, “These legislative efforts [the proposed de-funding rule] operate under the guise of protecting children. In reality, they punish caregivers and physicians when they choose to support children. They deny children access to routine health care that has been shown to decrease dramatically high rates of suicide and depression for TGD (transgender and gender diverse) youth. They fuel discriminatory rhetoric, which negatively impacts the mental health of TGD children and imperils their safety.”

 Thank you for the opportunity to comment in opposition to the proposed rules.

 Sincerely,

 

[your name]

 

 2.     Comment on Proposed Prohibition on Federal Funds to Medicare- and Medicaid-Certified Hospitals for Gender-Affirming Care for Minors

 To Whom It May Concern:

My name is [first and last name] and I live in [city and zip code]. I am writing in opposition to rule: (1) 42 CFS Part 482, CMS-3481-P, RIN 0938-AV87, prohibiting Medicare- and Medicaid-certified hospitals from receiving federal funds if they provide gender-affirming care to minors.

 [The rest of your comment can be what is in the template above.]

Resources

Numerous medical association position papers are linked at: glaad.org/medical-association-statements-supporting-trans-youth-healthcare-and-against-discriminatory

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