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Submit public comment to CMS/HHS in support of youth gender-affirming care + upcoming advocacy event

December 20, 2025 1:01 PM | Iain Jasko (Administrator)

Hi all--

This message is from Gaylesta's Advocacy Committee to share major news from this week impacting youth access GAC, outline upcoming advocacy event, and provide ways to stay involved and informed.


This week's decision from CMS/HHS

As you may know from the emails sent out on the listserv earlier in the week, on Thursday the Centers for Medicare and Medicaid Service (CMS) released a ruling that has the potential to severely restrict or even eliminate trans youth's access to life-saving gender-affirming care if implemented. 

  • This ruling imposes a new "condition of participation" that would prevent hospitals and other healthcare institutions from providing GAC to trans youth in order to continue receiving medicare/medicaid funding.
  • While this ruling is not currently in effect and many healthcare institutions are continuing to provide GAC as usual, this could eventually lead to these institutions completely ending gender-affirming care for trans youth if the ruling stands.
  • More information on this ruling can be found here.


Upcoming Advocacy Committee Event

In early January, the Gaylesta Advocacy committee will be hosting a Zoom meeting for GAC providers outlining:

  • The implications of this decision
  • How it impacts our clients, their families, and us as providers 
  • How to navigate and hold these difficult conversations with families during this time of uncertainty

As part of this meeting, there are a couple of action items we'd like to facilitate participants in completing. 

  1. There's been an email template floating around from Rainbow Families Action that we can all send to various healthcare institutions to urge them to continue providing GAC to trans youth. If you click on this document, there's an easy to copy/paste email and a list of email addresses to send it to healthcare administrators at Kaiser, Stanford, UCSF, and Sutter urging them to continue providing youth GAC in spite of this recent ruling.
  2. There is a 60 day public commenting period following the release of the CMS ruling wherein we can all comment on the importance of GAC for youth and the damaging impact of this ruling, something we have a unique perspective on as mental health professionals. Public comments are being accepted now through February 17, 2026. During our zoom meeting in January, we'll be providing folks with a bulleted list of high-level talking points that you can utilize to craft your own public comment and we'll spend some time writing them together.

While a date for our meeting has not been set yet we're aiming to hold it sometime during the 3rd week of January, so more details to follow in the coming weeks! If you'd like to get involved in planning this meeting, please email advocacy@gaylesta.org


Submitting a public comment

If you're ready to submit a comment now or don't think you'll make it to our meeting, you can do so here: 

Link to submit a comment: https://www.federalregister.gov/documents/2025/12/19/2025-23465/medicare-and-medicaid-programs-hospital-condition-of-participation-prohibiting-sex-rejecting#open-comment

In your comment, please reference file code:  CMS-3481-P


We are all holding the heaviness and uncertainty that our clients, GAC providers, and the trans community are facing during this unsettling time. Through coming together, sharing resources, and taking action, we can collectively support one another while continuing to fight for the care trans youth need and deserve. We hope to see you at our upcoming event, and we deeply appreciate any action you are able to take in support of trans youth.


In Solidarity,

Your Gaylesta Advocacy Committee