The Trump Administration Threat To Transgender Adult Care Is Growing At Lightning Speed

Many transgender adults have wondered when their care would be banned by the Trump administration. Now, we are seeing the first vectors to do so.

Ted Eytan // Creative Commons

The assault on transgender adult healthcare has long been a quiet undercurrent in right-wing circles—now, it's breaking into full view. Anti-trans organizations have floated raising the age limit for care to 25 for years, and GOP architects of youth care bans have been explicit: the real goal is to eliminate gender-affirming care entirely. Donald Trump himself has vowed in the past to target trans healthcare “at any age.” Now, with a new letter from the Centers for Medicare and Medicaid Services (CMS) circulating to clinics nationwide, the first formal warning shots have been fired. Transgender adults should take notice—and prepare. The infrastructure to strip their care is already being built.

According to a recent CMS letter, clinics across the country are being warned against providing gender-affirming care to individuals under the age of 21. “Federal financial participation (FFP) is strictly limited for procedures, treatments, or operations for the purpose of rendering an individual permanently incapable of reproducing and, under 42 C.F.R. 441.253(a), is specifically prohibited for such procedures performed on a person under age 21,” the letter reads, citing a 1978 regulation restricting federal funding for sterilization. But gender-affirming care for adults rarely meets that definition. Many transgender men and women retain the ability to have children after temporarily stopping hormone therapy, and fertility counseling is routinely offered. When sterilization does occur, it is not the goal of the care—it is an incidental outcome of treatment meant to alleviate gender dysphoria.

More troubling is the use of this decades-old regulation to pressure health care centers into dropping transgender care for adults. The expansion of restrictions to include people up to the age of 21 follows a recent Trump executive order barring gender-affirming care for anyone under 19—a category that includes legal adults. Although that order has been blocked in multiple courts, hospitals have still used it to justify halting care for this population. Now, the CMS letter is having a similar chilling effect: Planned Parenthood of Arizona has “paused” gender-affirming care for all adult patients. This is a deeply alarming development, especially considering that Planned Parenthood is the largest—and often the only—provider of transgender adult healthcare in many parts of the country.

It appears increasingly likely that the Trump administration is preparing to target transgender adult healthcare nationwide. In his campaign video, Trump stated he intends to investigate gender-affirming care for transgender people of any age. At the same time, reports indicate the Department of Health and Human Services is preparing to release a junk science review targeting both transgender youth and adults, with one internal letter referencing plans to study the “chemical and surgical mutilation of children and adults.” The warning signs for transgender adults are blaring: when Republican legislators say behind closed doors that their goal is to end gender-affirming care “for everyone,” and when figures like Michael Knowles call for the “eradication” of transgender people at CPAC, this is what it looks like when those words begin turning into action.

It would not take much for transgender adult care to be severely disrupted. The forthcoming HHS report could be used to justify a national executive order threatening hospital funding for any institution that treats transgender adults. Given the widespread over-compliance already seen in response to executive orders with no statutory authority—whether around DEI rollbacks, the erasure of LGBTQ+ people, censorship of AIDS/HIV prevention resources, removal of critical historical narratives, or retaliation against law firms that challenge the administration—such an order could have sweeping, chilling effects. The threat of investigations alone could freeze care for countless trans people, forcing providers to pause services out of fear. These disruptions are already underway in Arizona following Planned Parenthood’s decision to halt transgender care—an early indication of the nationwide consequences should the Trump administration continue its campaign against transgender people unchecked.

Such steps have already been implemented in a state that appears to be a model for the Trump administration’s approach: Florida. In 2023, the state issued standards of care that led to sweeping rollbacks in access to gender-affirming care for both youth and adults—amounting to an effective ban for many. That was followed by further restrictions on providers, which resulted in the elimination of 80% of all transgender adult care in the state. Many transgender adults in Florida have since been forced to cross state lines to access basic medical treatment, and the number of in-state providers has plummeted under the weight of these new regulations.

Many transgender people have already begun taking steps to protect their access to care. If you are a transgender adult, it may be worthwhile to explore the options available to you. Some have worked with providers to secure multi-month prescriptions, a precaution many providers are now increasingly willing to accommodate. Others have chosen to slightly reduce their dosage to build up a reserve in case of long-term disruption. Still others have turned to gray-market or international sources for hormone therapy. While this publication does not endorse any specific course of action, it is important to research the available options and make informed decisions based on your circumstances.