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Family Research Council submitted a comment to the U.S. Department of Health and Human Services entitled, “Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2023.” This proposed rule would force insurers to cover “gender transition” procedures such as cross-sex hormones, puberty blockers, and sex reassignment surgery.

The comment stated in part: “There is a lack of scientific evidence to support the claim that gender affirmation practices account for any sustained reduction in Gender Dysphoria. There is evidence that puberty blockers, cross-sex hormones, and surgical procedures can cause permanent physiological damage and cause psychological harm. There is also a growing awareness of those who are unhappy with their gender affirmative care and have decided to detransition. Further investigation is needed to understand this population’s experiences and those who did not fare well following these medically-based practices. Given the aforementioned reasons, at minimum, these practices should be put on hold until better evidence exists, but they should certainly not be encouraged through the current proposed rule.”

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Dr. Jennifer Bauwens, Director of the Center for Family Studies at Family Research Council, who authored the comment, added: “Given the use of highly physiologically invasive practices associated with “gender-affirmative care,” the nature of these “interventions” should necessitate the highest standard and quality of evidence (e.g., sampling, design). Instead, many of the studies used to support these practices are from cross-sectional studies and are therefore limited in their ability to evaluate the impact of major life-altering pharmaceuticals and surgeries, particularly on minors.”

Bauwens continued, “It is hard to imagine any reputable physician who would recommend someone remove a kidney or other organ because the findings from a web-survey concluded that the absence of this organ produced better mental health outcomes. But this is happening in gender clinics every day in the U.S.”

Mary Beth Waddell, Director of Federal Affairs for Family and Religious Liberty at Family Research Council, also said: “What is being proposed here by HHS is uncalled for and largely unknown. We should not rush into advancing a policy which will cause harm to many people many years down the road. One thing that’s increasingly clear in recent years is the regret that many experience after being rushed into gender transition procedures or supposed treatments. We must not perpetuate this regret by pushing more down this road, which this proposal does.”

To read the full comment, visit https://downloads.frc.org/EF/EF22A32.pdf.

In addition to our comment, we submitted material showing the harms of gender transition to children, concerns about ethical standards in this area, and how other countries are recognizing the harms associated with these procedures.

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