On February 17, 2026, the National Women’s Law Center submitted a comment in opposition to the Department of Health and Human Services’ (HHS) attack on coverage of essential care for transgender youth. HHS proposed a rule that would bar federal funds from being used to cover health care for transgender youth under Medicaid and the Children’s Health Insurance Program (CHIP).
In our comment, we lay out why the proposed rule is dangerous, groundless, and contrary to the law. For example:
- If it is finalized, the rule would jeopardize the health, safety, and wellbeing of transgender youth. The rule could also harm others, including intersex people, the families and providers who support trans youth, and the trans community broadly.
- Even though HHS says that this rule is driven by science, the evidence strongly suggests this claim is a pretext for anti-transgender prejudice.
- HHS ignores the large body of scientific evidence showing that health care for trans youth is safe, effective, and even lifesaving, and instead it resorts to disinformation to back up its proposed rule.
The proposed rule conflicts with the purpose of Medicaid and CHIP and with legal requirements that protect young people’s access to medically necessary care in these programs.
Find the comment here.