How To Submit Public Comments To Oppose Proposed Rules Restricting Transgender Health Care Access

On December 18, 2025, the U.S. Department of Health and Human Services announced two new proposed rules that would restrict access to best-practice medical care for transgender youth. The public can submit comments on the proposed rules until February 17, 2026.

The proposed rules by the Centers for Medicare and Medicaid Services rename this health care “sex-rejecting procedures” and include in that new category “any pharmaceutical or surgical intervention that attempts to align an individual’s physical appearance or body with an asserted identity that differs from the individual’s sex.”

These proposed rules are an aggressive use of executive power to curtail access to health care that the Trump administration dislikes. Currently, 27 states have enacted a ban on transition-related care for youth, but 26 states have explicit protections in place for this health care in their Medicaid plans. Finalizing these rules will lead to a chilling effect for providers of transgender health care and a further reduction in access to this care across the country. The proposed rules could lead to hospitals and providers stopping care of trans youth to maintain their federal funding and forcing families to pay for this care out of pocket. The proposed rules will also decrease health care access for trans people, a population that already faces barriers in affordability and insurance coverage.

This toolkit will:

• Introduce the proposed rules.
• Explain how to submit a comment.
• Provide suggestions on how to format and what to include in the comment.
• Give key statistics on the populations affected by the proposed rules.

Proposed rules

Medicaid and CHIP funding restrictions rule

This proposed rule would prevent federal funds from being used to pay for transition-related health care for youth covered by a state’s Medicaid or Children’s Health Insurance Program (CHIP), but states may still use their own non-federal funds to cover the costs for those treatments.

Hospital conditions of participation rule

This proposed rule seeks to require hospitals to cease providing transition-related care to individuals younger than 18 in order to maintain their federal Medicaid funding.

How to submit a comment directly to the Federal Register

• Visit the webpage for both proposed rules on the Federal Register.
  • Funding Restrictions and Conditions of Participation
• Click on the green “Submit a Public Comment” button beneath the rule title.
• Type your comment. You may also attach it as a Word document or PDF.
• Enter your email address if you choose to provide it. You can also select the checkbox to opt to receive email confirmation of your submission and a tracking number, but it is not required.
• Select whether you are an individual or an organization or whether you want to be anonymous.
  • Note that all comments are made viewable to the public even if you select “anonymous.” If you select “individual” or “organization,” the content of the comment and your name will be made viewable to the public.
• Select the box that says, “I read and understand the statement above.”
• Review your comment and click “Submit comment.” You may also preview your comment if you would like.

Format and outline for comments

Introduction: Introduce yourself and your connection to transgender health care. You can include things such as your profession or personal experiences.

State your position on the proposed rule: It is important to clearly state that you do not support the proposed rule and do not want the government to restrict access to medical care for transgender youth.

Explain why you care: This is your chance to talk about why preventing access to transgender health care is discriminatory and will lead to negative health outcomes for transgender youth. The federal government is taking away the rights of families, patients, and providers to make the best health care choices for transgender youth.

Include unique, real-life information: You can share personal stories about the importance of having access to health care or about how transition-related care has affected your life or the life of someone you know. Use caution when sharing easily identifiable information, such as your full name or home address, in your public comment since the comments are viewable by everyone who visits the Federal Register.

Here are some topics you can discuss:

• What has it meant for you or your family to receive the health care needed to live safely and authentically.
• The kinds of barriers you have already encountered regarding transgender health care and what would happen if that care was harder to access.
• Information about the negative impacts of limiting access to health care for trans youth, especially through the types of policies proposed in these rules.

Medical providers may also want to include information on:

• The safety and efficacy of transition-related care for transgender youth.
• How access to health care has improved the lives of patients and their families.
• Concerns about the impact of health care restrictions for transgender youth and low-income families who rely on Medicaid or Children’s Health Insurance Program (CHIP) insurance coverage.

Conclusion: Summarize your main points and restate your opposition to the proposed rules.

Key points to include in your public comments

• There are an estimated 724,000 transgender youth between the ages of 13 and 17 in the United States.
• As of August 2025, 77.3 million people in the United States were enrolled in Medicaid/CHIP.
• In 2024, 16 percent of transgender adults did not have health insurance.
  • 28 percent of transgender adults with insurance coverage relied on Medicaid and 7 percent of LGBTQI+ households with insurance coverage relied on CHIP.
• 39 percent of transgender adults avoided preventive health care in 2024 due to cost barriers.
• Analysis of major private insurance coverage shows that transition-related care is frequently covered, and 26 states have policies protecting access to this medical care for Medicaid recipients.
• Policy attacks on the transgender community have negatively affected the well-being of transgender youth.
• The types of health care services that would be blocked by these proposed rules are safe, effective, and are supported by many major medical associations in the United States.

Conclusion

The Trump administration is scapegoating transgender people and their health care at every turn and the proposed rules are just another item in the list of discriminatory policies that the administration has advanced in the past year. It is important that members of the public make their voices heard to protect access to medical care for transgender youth and to ensure that health care decisions are guided by accurate medical and scientific information, not by ideology.