New HHS Directive Cites Anti-LGBTQ+ Hate Groups, Demands Hospitals Stop Trans Youth Care

The memo went out on Wednesday from the Centers for Medicare & Medicaid Services at HHS, and threatens to pull funding from hospitals that do not comply.

On Wednesday, the Centers for Medicare & Medicaid Services (CMS), an agency within the U.S. Department of Health and Human Services (HHS), issued a memo to federally funded hospitals, suggesting they comply with President Donald Trump’s recently enjoined executive order restricting gender-affirming care for minors.

The memo is entirely unenforceable, serving only as a statement of the prevailing opinion within CMS. However, because Trump’s executive order hinges on threats to revoke federal funding from noncompliant hospitals, it carries an implicit warning that the administration may ignore this week’s court ruling blocking enforcement. This concern is reinforced by the memo’s closing remarks, in which CMS vaguely states, "CMS may begin taking steps to appropriately update its policies to protect children from chemical and surgical mutilation. CMS will follow any applicable substantive and procedural requirements in taking any future action."

The memo and its accompanying press release are rife with scientifically inaccurate claims, often misrepresenting even their own sources. One glaring example is their citation of the Mayo Clinic’s webpage on puberty blockers for gender dysphoria. The memo asserts that puberty blockers have "harmful long-term" effects and are "irreversible," yet the Mayo Clinic’s own webpage makes no such claim.

Instead, the cited page acknowledges that puberty blockers may temporarily affect bone density, growth, and fertility while in use, but it does not describe these effects as long-term or harmful. In fact, the same document directly contradicts the "irreversible" claim, stating, "GnRH analogues don't cause permanent physical changes. Instead, they pause puberty. That offers a chance to explore gender identity. It also gives youth and their families time to plan for the psychological, medical, developmental, social and legal issues that may lie ahead."

The memo relies heavily on anti-trans activist groups to support its claims, including multiple organizations designated as anti-LGBTQ hate groups by the Southern Poverty Law Center, such as the misleadingly-named Society for Evidence-based Gender Medicine (SEGM), Do No Harm, and American College of Pediatricians.

One of its central claims—that more than 80% of transgender youth will eventually cease identifying as trans—comes from the infamous 2013 study by Thomas Steensma. This statistic has been widely debunked, including in prior reporting by Erin in the Morning, as the studies used to support it suffer from serious methodological flaws that either prohibit or directly contradict the interpretations favored by anti-trans groups—for example, most kids in these studies were likely not even transgender.

The memo also cites a non-peer-reviewed letter to the editor, paid for by SEGM, as supposed evidence of harm caused by gender-affirming care. It fails to mention the letter’s clear bias or the lack of rigorous scientific review behind it.

The memo also relies heavily on the Cass Review, the controversial 2024 report that led to a ban on gender-affirming care for minors across the United Kingdom. Despite widespread criticism from medical experts, the Trump administration has embraced the review, even as the British Medical Association condemned it as biased and based on cherry-picked, ideologically driven information.

In an attempt to build international consensus, CMS falsely claims that Sweden and Finland have both issued “restrictions” on gender-affirming care, implying that their policies align with Republican efforts in the U.S. However, these claims are misleading. PolitiFact reports that Sweden implemented only mild restrictions on gender-affirming surgeries for minors under 18—a procedure already exceedingly rare. These policies are not new but rather extensions of long-standing laws, and minors can still access care in "exceptional cases." Similarly, Finland has not banned gender-affirming care but issued recommendations, primarily concerning surgeries. Transgender youth in Finland still have access to care, and recent efforts to impose further restrictions have been linked to actors affiliated with anti-trans hate groups.

The few citations not tied to anti-trans actors are also severely misrepresented by CMS. They cite a 2022 study by the Williams Institute to support their claim that transgender minors are prone to detransitioning—a conclusion the study neither supports nor suggests.

Finally, CMS cites a 2020 study on neurodevelopmental experts’ opinions to suggest that puberty blockers harm neurological development in transgender minors. However, the study is misrepresented—it is neither a literature review nor original research but a call for further study on the topic. The quoted statement is from the introduction and does not provide evidence supporting CMS’s claim.

Expert consensus has since evolved. The eighth edition of the World Professional Association for Transgender Health’s Standards of Care states that while data on neurological effects is limited, current research supports gender-affirming care as leading to positive outcomes, with delays posing potential harm. Major medical organizations, including the American Medical Association, the American Psychological Association, and the American Academy of Pediatrics, continue to affirm gender-affirming care as safe, necessary, and effective.

Contrary to claims that the United States is an "outlier" in gender dysphoria treatment, gender-affirming care for minors— including puberty blockers— is widely supported by medical professionals worldwide. The French Society of Pediatric Endocrinology and Diabetology conducted a review last year overwhelmingly endorsing gender-affirming care for minors. In Australia, multiple medical associations have issued statements in support of such care, while the Canadian government explicitly endorses it. Additionally, the World Medical Association has issued an authoritative statement backing gender-affirming treatment.

Gender affirming care is based on rigorous scientific evidence. A literature review from Cornell University found that gender affirming care significantly lowers the risk of suicidality in transgender youth via protective effects on mental health. German medical organizations conducted a systematic review of the literature, arguing that depriving youth of treatment is incredibly harmful. Additionally, a study from Nature Human Behavior from last year found that anti-trans state laws increase suicide attempts by upwards of 72% in young people.

This CMS memo offers nothing new to those familiar with the standard talking points of opponents to gender-affirming care. It underscores the Trump administration’s willingness to rely on fringe hate groups over the overwhelming consensus of leading medical bodies in the U.S. and around the world. While ideologically driven narratives dominate federal policy, the scientific evidence remains clear. No matter how aggressively Republicans attempt to distort the facts, history has consistently placed them on the wrong side of medical and civil rights advancements. Transgender rights are no exception.