GLMA Condemns New Proposed CMS Rules Targeting Care for Transgender Youth; Encourages Health Professional Participation in Public Comment Period
PRESS RELEASE
FOR IMMEDIATE RELEASE
December 18, 2025
Contact: Eli Duffy; Director of Communications & Strategic Partnerships
eduffy@glma.org
WASHINGTON, DC – Today, the U.S. Department of Health and Human Services (HHS) announced two proposed rules from the Centers for Medicare & Medicaid Services (CMS) that aim to restrict access to medically-necessary care for transgender youth nationwide.
The proposed rules:
“Hospital Condition of Participation: Prohibiting Sex-Rejecting Procedures for Children” (CMS-3481-P)(RIN 0938-AV73) – Would prohibit hospitals that offer care for transgender youth from participating in Medicare and Medicaid and cut them off from this stream of federal funding entirely.
“Prohibition on Federal Medicaid and Children’s Health Insurance Program Funding for Sex-Rejecting Procedures furnished to Children” (CMS-2451-P) (RIN 0938-AV87) – Would prohibit the use of federal Medicaid and CHIP funding to cover medically necessary care for transgender youth. This could make it even more difficult for transgender young people to receive the care they need.
Importantly, these
proposed rules are not final and do not amount to a ban on care for transgender youth. These rules do represent an unprecedented attempt to severely limit access to critical care through government coercion. What is clear is the intent behind these actions: to insert the federal government into deeply personal medical decisions that should remain with patients, families, and clinicians.
Independent research, including a
comprehensive multi-year review commissioned by the state of Utah, shows that care for transgender youth improves mental health and well-being, and has extremely low rates of regret. And every major U.S. medical and mental health association recognizes this care as medically necessary and effective.
The medical community must take action to prevent this blatant government overreach from dictating the provision of care. The rules are
subject to a public comment process that provides a critical opportunity to influence the outcome and
GLMA encourages all health professionals to engage in the process.
“These proposed rules have nothing to do with protecting children or improving care,” said Alex Sheldon, MA, Executive Director of GLMA. “They aim to weaponize federal funding to coerce providers and hospitals into abandoning evidence-based medicine, setting a precedent that threatens medical decision-making far beyond transgender patients.
We urge the health professional community to collectively push back and engage in every available avenue to prevent these rules from taking effect.”
“These proposals are grounded in a deeply flawed HHS report that does not reflect accepted medical science,” said Jona Tanguay, MS, PA-C, AAHIVS, CAQ-Psych (they/them), President of GLMA. “When federal agencies issue regulatory guidance that disregards evidence and clinical consensus, the result is fear, confusion, and disrupted care for transgender patients, even in states where this care remains lawful. That outcome is a predictable consequence of this approach. Health professionals remain ethically obligated to provide medically necessary care, and no regulation can erase decades of established standards or our responsibility to our patients.”
Coinciding with these rules, the U.S. Food and Drug Administration (FDA) issued warning letters to multiple manufacturers and retailers regarding the marketing of chest binders when used by transgender people to alleviate gender dysphoria. At the same time, HHS is moving to reverse the Biden administration’s effort to recognize gender dysphoria as a disability under federal civil rights law through a proposed revision to Section 504 of the Rehabilitation Act of 1973 that would reverse prior efforts to recognize gender dysphoria as a disability, explicitly excluding it from disability protections to ensure that new restrictions on so-called “sex-rejecting procedures” do not violate nondiscrimination requirements. Taken together, these combined actions signal an aggressive effort to narrow civil rights protections, stigmatize medically necessary care, and limit avenues for legal recourse for transgender patients and the providers who serve them.
About GLMA: Health Professionals Advancing LGBTQ+ Equality
GLMA is a national organization committed to ensuring health equity for lesbian, gay, bisexual, transgender, and queer (LGBTQ+) communities and equality for LGBTQ+ health professionals in their work and learning environments. To achieve this mission, GLMA utilizes the scientific expertise of its diverse multidisciplinary membership to inform and drive advocacy, education, and research.
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