Insights

Since the signing of Executive Order 14187 (“Protecting Children from Chemical & Surgical Mutilation”) in late January 2025, the Trump Administration has made its skeptical stance on gender-affirming care—especially regarding services provided to minors—clear.

On August 19, 2025, the Office of Personnel Management (OPM) informed insurers participating in the Federal Employees Health Benefits or Postal Service Health Benefits programs that gender-affirming care would no longer be covered for federal workers starting in 2026. This coverage decision is the Trump Administration’s latest action stemming from Executive Order 14187 which aims to prevent certain treatments, such as gender-affirming hormone therapy, surgeries, and puberty blockers for those under the age of 19. As previously discussed, the Administration has also signaled its intent to use various law enforcement tools against gender-affirming care, including  Section 5 of the Federal Trade Commission Act to police false or unsupported claims by medical professionals about gender-affirming treatments.

On May 28, 2025, Centers for Medicare and Medicaid Services (CMS) Administrator Mehmet Oz sent a letter to select hospitals requesting information about the hospitals’ practices related to treatment for gender dysphoria in children. The letter also requests financial information related to pediatric gender-affirming care paid for “in whole or in part” by the federal government.

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In the second of a two part series on the impact of administrative law in the health care industry, hosts Payal Nanavati and Savanna Williams talk to Dan Wolff about the practicalities of seeking judicial review to challenge agency actions, the impact of Loper Bright, and the major questions doctrine.This podcast episode features the following speaker: