After Cutting Gender-Affirming Care For Federal Employees, the Trump Administration’s Endgame For Trans Healthcare Approaches

Behind the new federal employee health plan rule lies the Trump administration’s true goal: to brand gender-affirming care as unneeded.

Last week, the Trump administration quietly announced that gender-affirming care would no longer be covered for federal employees beginning in 2026. Well, almost: the memo includes a carve-out for ‘counseling services for possible or diagnosed gender dysphoria.’ While it’s certainly true that therapy is an important part of transitioning, under these new rules, companies must also cover ‘faith-based’ gender dysphoria counseling as long as it’s provided by ‘a licensed mental health provider.’

In other words, the federal government has mandated conversion therapy insurance coverage not just for federal employees, but also for their dependents. Although transgender adults are unlikely to seek conversion therapy themselves, this facilitation of conversion therapy access could prove devastating for trans children of federal employees whose parents are hostile to their identities. However, this memo also exposes the truth, because for the first time, the Trump administration’s end goal for their attacks on the trans community has come into view.

Everything In Their Power

Ever since Trump entered office back in January, it seems that the federal agencies, under the tight command of the president, have tried to do everything in their power to make life harder for trans Americans. These attacks have been an onslaught, reaching everything from passports to sports, bathrooms, and more. Simply put, in the past 8 months, things have gotten worse for us in almost every conceivable way. Here’s a summary of all federal action:

For maps and tables breaking down state-level policies for these issues, head to Transitics’ CATPALM page.

Putting everything together, something becomes clear: with a few exceptions, everything concrete that Trump has done is the most that he can do. Many things, such as Social Security, passports & CRBAs, the military, prisons, and federal buildings, are solely under federal control, and as such, changes to their policies can be fairly easy. However, gender-affirming care for minors and sports can only be affected through threatening to revoke federal funding, which works to a certain extent but doesn’t ban these in their entirety. Meanwhile, a longtime target of the Republican Party, Medicaid coverage of gender-affirming care, cannot be banned at the federal level without the support of at least 60 senators.

However, formal policy action is not the only action that can be taken. These orders mainly provide guidance, but federal agency heads can choose to go further. Case in point: the Office of Personnel Management, whose ban on gender-affirming care coverage by federal employee health plans was never stipulated in any executive order (though an exclusion for those under 19 was mandated by EO 14187). Furthermore, parallel to Trump’s executive orders, RFK Jr.’s Department of Health and Human Services has slowly worked to lend ‘credibility’ to the pseudoscientific belief that gender-affirming care is dangerous to trans people.

A Carefully Spun Web

Back in May, the HHS published a report on the medical treatment of transgender youth. This report, an American equivalent of the UK’s Cass Review, asserted that the best approach to gender dysphoria is psychotherapy and not gender-affirming care. However, unlike the Cass Review, it doesn’t serve to directly change policy—far from it. Like I said when it was published, it’s primarily a weapon. It serves as a way to legitimise gender-affirming care bans at the state level (which were upheld by the Supreme Court) and the federal level, which has sparked a courtroom showdown between Democratic state attorneys general and the Trump administration.

Then, in June, the HHS took it a step further by finalising a new rule that removes gender-affirming care coverage as an Essential Health Benefit under the Affordable Care Act. Under this rule, federally regulated ACA marketplace insurance plans will not cover gender-affirming care unless you’re a California, Colorado, New Mexico, Vermont, or Washington resident beginning in 2026. But in both of these cases, beyond the obvious, transphobic jargon is something even more sinister: the growing narrative that gender-affirming care isn’t necessary for any of us.

There’s no doubt that the push to brand gender-affirming care as unnecessary is behind the changes to Federal Employee Health Benefits. And unlike most recent federal attacks, the HHS’ damage to gender-affirming care is not easily undone. Their amplification of attacks against adult healthcare could have drastic consequences for other health plans outside of federal control, too. Already, 11 states (plus Ohio, which has conflicting policies) explicitly exclude trans healthcare from their Medicaid plans, with Iowa, Kentucky, and Louisiana all having stopped coverage this year. Moreover, another 10 states have no official policy. See the full map here:

See CATPALM’s main article for sources.

Additionally, I imagine private insurers are more than eager to pounce on being able to deny healthcare for yet another group of people. If they think they have grounds to deny gender-affirming care coverage and think the HHS’ stated opinions give them a way out, who’s to stop them from trying it?

The good news is, blue states have protections that force private insurance companies to cover our care. However, there is one exception to these shield laws, found in Title 5 of the United States Code, Section §8902(m), and that is for federal employee health plans. So if the judicial system rejects what will be an inevitable challenge to this policy, that will be that. Unfortunately, it’s the only nationwide healthcare exclusion that can’t be mitigated by state-level protections, and they’ve taken full advantage.

At the end of the day, the Trump administration’s actions are mainly for political theatre. The executive order signing ceremonies, pressure on colleges like UPenn, and rants about transgender mice are all for show. But the attacks on our healthcare? They don't make a scene. Because those attacks have one purpose: to hurt us for the sake of hurting us. That is their endgame.