KFF December 22, 2025
Lindsey Dawson, Scott Hulver

On December 18, 2025, the Centers for Medicare and Medicaid Services (CMS) issued two proposed rules that would further limit youth access to gender affirming care. One rule would change the hospital Conditions of Participation (CoPs) which would prohibit most Medicare and Medicaid enrolled hospitals from providing specified gender affirming medical care for youth (the proposed CoPs rule). The second proposed rule would prohibit federal Medicaid or CHIP funds from covering this care for youth (the proposed Medicaid rule). Despite gender affirming care being considered a best practice model of care and consisting of interventions recommended by major medical associations, if finalized and implemented, the proposed rules would have a sweeping impact, albeit for a small number of young people,...

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