On May 28, 2025, the Centers for Medicare & Medicaid Services (CMS) sent a letter to “select hospitals” that provide gender-affirming care services, requesting information about how those hospitals adhere to quality standards regarding medical interventions for gender dysphoria in minors, as well as financial data for gender-affirming care procedures provided at the hospitals and paid, in whole or in part, by the federal government.
CMS likely considers the request to be within its authority to enforce Medicare and Medicaid conditions of participation as evidenced by the letter’s reference to CMS’s “obligation to ensure baseline quality standards.” CMS also cites previous Trump administration actions regarding gender-affirming care for minors as support for the request, including the original executive order, a report from the US Department of Health and Human Services (HHS) reviewing best practices for gender dysphoria treatment (GAC report), and a quality and safety special alert memo for hospitals. Despite these actions, no statutory or regulatory changes to hospitals’ ability to continue providing gender-affirming care services have been promulgated to date. As a result, the letter raises several questions, such as those outlined in this FAQs document.
