Leave a Public Comment against federal bans on trans healthcare: Deadline Feb 17
Submit a Public Comment Directly at https://www.regulations.gov/commenton/CMS-2025-1823-0001 and https://www.regulations.gov/commenton/CMS-2025-1822-0001
Two HHS rules are in a public comment period that could cause serious harm to trans healthcare. The deadline is February 17.
Please leave a comment on these two sites at regulations.gov. Doing so will help lay the groundwork for legal challenges to the law in the future or, more ideally, prevent them from passing into law in the first place.
Make a public comment about the proposed rules barring medical care for trans youth:
https://www.regulations.gov/commenton/CMS-2025-1823-0001
Make a public comment about the proposed rule barring medicare and medicaid funding for hospitals that provide gender-affirming care:
Talking Points
(Note: below are talking points you can use to craft your own statement. Public comment works best when every comment is unique, well-researched and personally relevant. Talk about who you are and why you care)
A sample script is below:
I am deeply concerned with the proposed rules as stated in the "Prohibition on Federal Medicaid and Children's Health Insurance Program Funding for Sex-Rejecting Procedures Furnished to Children" (File code CMS-2451-P). [INSERT WHY YOU CARE]. At the end of the day, I care about children and I care about laws and regulations coming from the government being truly in the best interests of the children they are impacting. That is not the case with this proposed regulation.
Specifically, I object to the proposed rule for two reasons:
(1) the proposed rules are based on the HHS's white paper called "Treatment for Pediatric Gender Dysphoria" released on November 19th, 2025, which was peer reviewed and found to lack "the standard of methodological rigor that should be considered a prerequisite for policy guidance in clinical care." (Per the American Psychiatric Association's peer review of the report.) Despite these shortcomings, HHS has based their rules entirely on the support of this faulty report, which has been misconstrued to the American people as "peer reviewed" as though that makes it more trustworthy. The peers have done their review, and they find the report lacking. This is no way to go about making rules purportedly based on science or on the best interests of children.
(2) The best interests of children are not served by these rules. Major mainstream medical associations – including the American Medical Association, the American Psychiatric Association, the Endocrine Society, the American Psychological Association, the American Academy of Pediatrics, and the American Academy of Child & Adolescent Psychiatry--all support gender-affirming (or "gender-rejecting" as the rules call it) care for trans youth. While gender-affirming surgeries do occur in a small fraction of the trans youth who receive medical care, the vast majority of trans youth do not undergo irreversible surgeries.
Any parent who cares about the wellbeing of their child, and any doctor who puts the best interests of the child first, which is the vast majority of doctors, would never rush into any irreversible gender affirming care, or push hormones or other pharmaceutical interventions onto a child quickly or on a whim. For an administration that claims to care so deeply about parental rights and protecting children, HHS seems unwilling to allow the people closest to children and who are most concerned about their wellbeing (their parents and doctors) to do what they believe is best for the children, based on the medical expertise and guidance of every major mainstream medical association. This encroachment on the ability to parent is an infringement on parental freedom, and the outcomes are quite literally deadly for the suicidal trans youth who do not receive the support they need and are instead stigmatized and othered by an administration that claims to care about their best interests.
As such, it is my recommendation that these proposed rules not move forward as they would pose a grave danger to the health and wellness of the trans youth that HHS has purported to want to support and protect. Instead, it should be left to parents and their doctors, based on actually good data and science and the recommendations of major medical associations, to provide the support their individual child needs to be happy and to flourish. Instead, the HHS should focus its energy on providing quality mental and medical healthcare for trans youth, care that has proven effective at lessening their distress and mental health disorders that occur as a result of the very systemic marginalization that HHS is proposing to further with these new rules. For these reasons, I strongly oppose the proposed regulations in "Medicaid Program: Prohibition on Federal Medicaid and Children's Health Insurance Funding for Sex-Rejecting Procedures Furnished to Children" (File code CMS-2451-P).
Thank you for your efforts in protecting the dignity and lives of trans youth today!
Resources:
https://www.regulations.gov/document/CMS-2025-1823-0001
https://www.democracynow.org/2025/12/19/trans_healthcare
https://opa.hhs.gov/sites/default/files/2025-11/gender-dysphoria-report-supplement.pdf
Background
See our blog post on the dangers of blocking trans health care.