Since January 2025, the Trump administration’s restrictions on transgender healthcare have moved on several tracks at once: two executive orders, rulemaking at HHS and CMS, a Veterans Affairs rollback, an end to coverage in federal employee plans, and a Justice Department criminal investigation seeking patient records from hospitals. Federal courts have blocked or paused some of the biggest pieces, including the order conditioning federal funds on stopping care for people under 19, an HHS declaration calling the care unsafe, and several hospital subpoenas. Access now depends on your age, your state, your insurance, and whether your hospital has decided to keep offering care under federal pressure.
The Two Executive Orders That Set the Framework
On January 20, 2025, Trump signed an order defining sex as an immutable binary, prohibiting federal funding for “gender ideology,” and directing the Attorney General to block federal funds for procedures altering an incarcerated person’s appearance to match the opposite sex. The same order rescinded Biden-era executive orders that had supported LGBTQ+ nondiscrimination in healthcare.1KFF. Overview of President Trump’s Executive Actions Impacting LGBTQ Health
Eight days later, on January 28, 2025, Trump signed “Protecting Children from Chemical and Surgical Mutilation.” It defines “child” as anyone under 19, a wider bracket than most state bans, which usually stop at 17. The order directs HHS to rescind guidance relying on the World Professional Association for Transgender Health, use its authority over Medicaid, Medicare, and the ACA to end these interventions, and publish a new literature review within 90 days. It tells the Defense Department to exclude puberty blockers, cross-sex hormones, and related surgeries from TRICARE coverage for military dependents. It tells the Office of Personnel Management to exclude pediatric transgender surgeries and hormone treatments from federal employee and Postal Service plans starting in 2026. It directs the Justice Department to investigate providers for potential fraud, work with Congress on a private right of action for families, and investigate states with “shield” laws. Every agency that awards research or education grants to medical institutions was told to make sure recipients stop providing gender-affirming care to minors.2The White House. Protecting Children From Chemical and Surgical Mutilation
What Federal Insurance Now Covers
The coverage picture shifted quickly in 2025 and 2026, and it varies by program.
ACA Plans
On February 20, 2025, the HHS Office for Civil Rights rescinded the 2022 guidance interpreting Section 1557 of the ACA to prohibit discrimination based on gender identity in healthcare.3U.S. Department of Health and Human Services. OCR Rescission of Gender Affirming Care Guidance In May 2025, HHS rescinded the 2021 guidance that had extended Section 1557 protections to sexual orientation and gender identity, and told the Supreme Court the federal government no longer maintains that bans on transgender healthcare violate the Fourteenth Amendment’s Equal Protection Clause.1KFF. Overview of President Trump’s Executive Actions Impacting LGBTQ Health
On June 25, 2025, HHS finalized a rule prohibiting health insurers from covering “specified sex-trait modifications” as an essential health benefit under the ACA, effective for plan years beginning in 2026. If your plan previously covered these procedures as an essential benefit, you now pay out of pocket. Plans can still cover the care voluntarily as a non-essential benefit where state law allows, and states that mandate the coverage outside the benchmark would carry the cost themselves.4Westlaw. HHS Prohibits Coverage of Gender-Affirming Care as ACA Essential Health Benefits
Federal Employee and Postal Plans
OPM eliminated coverage for “chemical and surgical modification of an individual’s sex traits” from Federal Employee Health Benefits plans for the 2026 plan year, and the rule applies to enrollees of any age. Carriers were instructed to remove providers offering such modifications from their directories. Limited exceptions cover mental health counseling for gender dysphoria, patients already mid-treatment on a case-by-case basis, and hormone therapy prescribed for unrelated conditions such as cancer. The administration indicated all transition care coverage for federal and Postal Service employees would end starting in 2027.5Government Executive. Coverage for Gender-Affirming Care Will Be Eliminated From FEHB Plans in 20266NBC News. Trump Transgender Healthcare Changes for Veterans and Federal Employees
VA Care for Veterans
On March 17, 2025, the VA announced it would phase out treatment for gender dysphoria. Cross-sex hormone therapy is no longer offered except to veterans already receiving it through the VA or those who began treatment in the military and continued at separation. All other medical and surgical treatment was discontinued immediately, and the VA rescinded the directive that had authorized services including voice training and gender-affirming prosthetics. Secretary Doug Collins said veterans seeking gender-affirming care would need to pay “on their own dime.”7Department of Veterans Affairs. VA to Phase Out Treatment for Gender Dysphoria
Medicare, Medicaid, and Hospital Participation
On December 18, 2025, HHS Secretary Robert F. Kennedy Jr. signed a declaration stating that gender-affirming medical procedures for minors are “neither safe nor effective” and that practitioners performing them are “out of compliance” with recognized standards of care. That same day, CMS proposed two rules: one barring any hospital that receives Medicare or Medicaid funds from providing gender-affirming pharmaceutical or surgical services to anyone under 18, regardless of who pays; and one cutting off federal Medicaid funding for such services for children under 18 and CHIP funding for people under 19.8Centers for Medicare & Medicaid Services. HHS Acts to Bar Hospitals From Performing Sex-Rejecting Procedures for Children
Both proposals went through a 60-day comment period and, as of mid-2026, had not been finalized.9KFF. New Trump Administration Proposals Would Further Limit Gender-Affirming Care for Young People The Kennedy declaration itself was struck down in court (see below). The FDA also issued warning letters to 12 manufacturers and retailers about marketing chest binders to children for gender dysphoria.8Centers for Medicare & Medicaid Services. HHS Acts to Bar Hospitals From Performing Sex-Rejecting Procedures for Children
The DOJ Investigation and Hospital Subpoenas
The Justice Department opened a broad criminal investigation into providers of gender-affirming care and convened a grand jury in the Northern District of Texas. After federal judges blocked numerous administrative subpoenas across 2025, the DOJ turned to criminal grand jury subpoenas to compel hospitals to produce detailed patient records.10NPR. Transgender Youth Healthcare Trump Subpoena
The subpoenas seek identifying information and medical records for adolescent patients who received transition-related care over the preceding six years. NYU Langone publicly disclosed receiving one in May 2026 and said it was “one of several institutions” targeted. Lucile Packard Children’s Hospital at Stanford was also identified as a recipient. The DOJ said the investigation looks at potential healthcare fraud, false statements, and illegal off-label drug use, and that the probe “is not—and has never been—an investigation of patients or parents.”11CNN. Trump Administration Trans Minors Medical Records As of mid-2026, no criminal charges had been brought against any provider.12KFF. Texas Emerges as Focus of New Trump Administration Actions to Limit Gender-Affirming Care
In a separate civil matter, Texas Children’s Hospital reached a settlement with the DOJ and the Texas Attorney General on May 15, 2026, over allegations of “false billing.” The hospital denied all allegations and said it settled “to protect our resources from endless and costly litigation.”12KFF. Texas Emerges as Focus of New Trump Administration Actions to Limit Gender-Affirming Care
What Courts Have Blocked
Federal courts have paused several of the largest measures.
The Funding Cutoff for Providers
In PFLAG v. Trump, the U.S. District Court for the District of Maryland issued a temporary restraining order on February 13, 2025, and a nationwide preliminary injunction on March 4, 2025, blocking enforcement of the executive orders’ directives to withhold federal funds from providers offering gender-affirming care to people under 19. Judge Brett H. Harris ruled the orders likely exceeded presidential authority by conditioning federal funding in ways Congress had not prescribed, citing Clinton v. City of New York, and likely violated equal protection principles, citing Bostock v. Clayton County.13FindLaw. PFLAG, Inc. v. Donald Trump, Civil No. 25-337-BAH The injunction lets doctors and hospitals nationwide continue providing care while the case proceeds. The Fourth Circuit has repeatedly denied government requests to stay the injunction, and the appeal remains pending.14Lambda Legal. PFLAG v. Trump
The Kennedy Declaration
On April 18, 2026, U.S. District Judge Mustafa T. Kasubhai vacated Secretary Kennedy’s December 2025 declaration in State of Oregon et al. v. Kennedy et al., a case brought by 21 states and the District of Columbia. The court found the secretary exceeded his statutory authority and violated procedural requirements under the Administrative Procedure Act and the Medicare Act, and that the declaration “effectively eliminated any consideration of any standard of care” for people seeking gender-affirming care in the plaintiff states.15Courthouse News Service. Federal Judge Blocks RFK Declaration Targeting Gender-Affirming Care A permanent injunction bars HHS from enforcing the declaration or a materially similar policy in the plaintiff states. As of June 2026, the administration had not appealed.16Georgetown Law Litigation Tracker. State of Oregon et al. v. Kennedy et al.
The Medical Records Subpoenas
On June 8, 2026, a federal judge in the Northern District of California issued a temporary restraining order blocking hospitals statewide from complying with DOJ criminal subpoenas for transgender youth medical records, in a case brought by six families whose children received care at Stanford.17National Center for LGBTQ Rights. Court Stops Enforcement of Trump Administration’s Grand Jury Subpoena On June 24, 2026, Judge Katherine Polk Failla of the Southern District of New York issued a temporary restraining order in Coe v. Blanche, blocking the DOJ from obtaining records from NYU Langone and Mount Sinai for any patient treated for gender dysphoria while under 18 between January 2020 and May 2026. Judge Failla described the effort as a “concerted effort to obtain deeply private information about an entire class of individuals without their knowledge or consent.” The ACLU noted that at least eight federal district courts had previously blocked the DOJ’s administrative subpoenas, with one court calling the government’s reasoning a “smokescreen.”18ACLU. Judge Blocks Trump Administration Attempt to Seize Private Medical Records of Trans Youth
Federal Prisons
In Kingdom v. Trump, three transgender people in federal custody filed a class action representing roughly 2,000 transgender people in federal prisons, challenging the cessation of hormone therapy, restrictions on gender-affirming clothing, mandated use of incorrect pronouns, and transfer of transgender women to men’s facilities. The U.S. District Court for the District of Columbia certified the class and granted a preliminary injunction in June 2025, extended multiple times since. Cross-motions for summary judgment were being briefed as of June 2026.19ACLU. Kingdom v. Trump
Why Hospitals Have Stopped Offering Care Anyway
Even where the funding-cutoff order is blocked, hospitals across the country have voluntarily paused or ended gender-affirming care for minors under the combined weight of proposed rules, funding threats, and federal investigations. By early 2026, more than 40 hospitals and health systems had paused or ceased some form of this care. At least 15 had stopped all gender-affirming care for minors, and nine had specifically discontinued hormones and puberty blockers since the start of 2026.20STAT News. Hospitals Stop Gender Care for Minors Under Trump Administration Pressure
Children’s Hospital Colorado suspended care after a referral to the HHS Office of Inspector General, citing “risk to Medicare and Medicaid funding.” Lurie Children’s in Chicago paused gender-affirming medications for new patients under 18. Children’s Minnesota and Rady Children’s Health in California stopped providing medications to patients. Children’s Wisconsin cited “escalating legal and federal regulatory risk,” and UW Health paused prescribing puberty blockers and hormone therapy for patients under 18.21WPR. Children’s Wisconsin, UW Health Stop Providing Gender-Affirming Treatments to Minors Children’s Hospital Los Angeles said it would shutter its Center for Transyouth Health and Development on July 22, 2026, citing “increasingly severe impacts of federal administrative actions,” including threats from the DOJ, HHS, and CMS, and the FBI’s solicitation of tips to report providers.22Los Angeles Times. Children’s Hospital of Los Angeles Transgender Care
How This Stacks With State Law
Federal action layers on top of a divided state landscape. As of early 2026, 27 states had enacted laws banning access to gender-affirming care for minors, affecting roughly 362,900 transgender youth, and 17 states prohibited the use of Medicaid funds for such care. Six states and one territory made providing certain forms of care a felony. Seventeen lawsuits were challenging state bans as of mid-2026, and a Montana judge permanently blocked that state’s ban in May 2025.23Movement Advancement Project. Bans on Best-Practice Medical Care for Transgender Youth24Williams Institute, UCLA School of Law. Impact of Anti-Trans Legislation on Youth
On the other side, 17 states and the District of Columbia had enacted “shield” laws to protect providers and families from out-of-state enforcement. Colorado expanded its shield law in April 2025 to require attestations that subpoenas are not related to out-of-state penalties for protected healthcare. Connecticut enacted a June 2025 law requiring entities to notify the state attorney general within seven days of receiving a subpoena for reproductive or gender-affirming health records that lacks patient authorization.25CDT. Shield Law Update Report
The federal proposals are designed to reach beyond state law by using Medicare and Medicaid funding as leverage. Even in the 26 states that cover gender-affirming care through Medicaid, the proposed CMS rules would cut off federal reimbursement. Twelve states already bar Medicaid from covering transition-related treatment regardless of age, and 14 ban state employee health plans from covering it.6NBC News. Trump Transgender Healthcare Changes for Veterans and Federal Employees
No major U.S. medical organization has changed its clinical guidance in response to the federal restrictions. The American Medical Association, the American Academy of Pediatrics, the Endocrine Society, and more than a dozen other professional groups continue to describe gender-affirming care as medically necessary and evidence-based.26NPR. Transgender Trump Medicare Medicaid Gender-Affirming Care27GLAAD. Medical Association Statements Supporting Trans Youth Healthcare