Medical Groups Promote Concealing ‘Gender-Affirming Care’ for Minors from Insurers, Watchdog Group Says

Prominent medical organizations have promoted skirting coding guidelines to conceal restrictions on “gender-affirming care” for minors by miscoding sex-change procedures as routine endocrine care, according to a report from a medical watchdog group.

“There is significant evidence showing that many of the organizations involved in the child transgender industry have (at the very least) promoted alternative billing practices to secure insurance reimbursement,” the report, released Thursday, reads.

Groups listed in the report include World Professional Association for Transgender Health (WPATH), the Campaign for Southern Equality, and QueerDoc, a telemedicine site dedicated to “gender-affirming” care.

Planned Parenthood of Southeastern Pennsylvania, which is itself a health-care provider, has publicly acknowledged that it uses generic endocrine disorder codes, rather than codes specific to gender dysphoria, when filing insurance claims related to so-called gender-affirming care. None of the organizations responded to requests for comment.

Numerous states and the federal government have banned providers and insurance companies from using Medicaid funding to cover hormonal therapies and surgical procedures that are intended to alleviate gender dysphoria in trans-identifying children and adolescents, given the lack of compelling evidence that such procedures, which come with permanent physical consequences, actually alleviate mental distress.

“By misrepresenting the medical procedures they are performing, providers can pass off transgender medicalization as, for example, routine endocrine care unrelated to pediatric medical transition,” the report reads. “These ‘loopholes’ may enable providers to get paid for procedures which otherwise may not be funded. In some cases, such practices may even be outright fraudulent or a means of evading state-level restrictions on child sex change interventions.”

In medicine, ICD-10 diagnosis codes are three- to seven-character alphanumeric codes that health-care providers use to designate diagnoses, injuries, and symptoms for medical billing and reporting.

WPATH, for example, in its 2021 training materials, encouraged providers to use “endocrine related” ICD-10 diagnosis codes for sex-change treatments, to ensure insurance reimbursement. The organization came under fire in 2024 after leaked internal documents revealed that its members had privately expressed doubts about the safety and efficacy of hormonal therapies and surgical procedures while continuing to advocate them publicly.

The Campaign for Southern Equality is a southern LGBT activist group focused on “help[ing] families of transgender youth nationwide navigate cruel bans on gender-affirming care,” according to its website. A fact sheet that was removed from the group’s website in March 2025 listed “insurance coding alternatives for trans healthcare.” The list of misleading codes, according to Do No Harm, was intended for providers to “avoid scrutiny and obfuscate sex-denying medical interventions.”

According to the ICD-10-CM Official Guidelines for Coding and Reporting, medical providers are required to “[c]ode to the highest level of specificity when supported by medical record documentation.” Yet, patients who do not suffer from endocrine disorders, but rather so-called gender dysphoria, are receiving the treatments under the guise of routine endocrine treatment.

Further, Planned Parenthood of Southeastern Pennsylvania, itself a health-care provider, said its use of endocrine ICD-10 codes is “to meet the needs of most insurance companies and patients,” noting it only “occasionally” uses a code that accurately represents a patient’s gender treatment. QueerDoc, a telemedicine site focused specifically on “gender-affirming care,” notes that “some providers use the code E34.9, Endocrine disorder, unspecified” in place of “F64.9, Gender identity disorder, unspecified” in a patient’s records.

Do No Harm found several indications that providers are using misleading coding to circumvent restrictions on gender-affirming care.

When trying to determine how “gender-affirming” procedures are being billed to insurance, there are two primary insurance claims databases to review and correlate: pharmacy claims for prescription fulfillment and medical claims (including office visits), the latter of which are billed using procedure codes along with ICD-10 diagnosis codes.

In order to associate the information between the claims, one must use the National Provider Identifier (NPI) to match the prescription with the office visit. The closer together the time frame is between when the prescription is filled and when the office visit is filed, the more confident one can be in the association — for example, if the prescription was written at that specific office visit.

“Once the association is made, one can then review the ICD-10 diagnosis code on the office visit claim,” according to the report. “For instance, a prescription claim for testosterone in an adolescent female within 3 days of an office visit without an F64 ICD-10 diagnosis code for that visit would raise concerns of potential miscoding of the office visit claim.” The F64 ICD-10 diagnosis code covers gender identity disorders.

Surgical codes paired with ICD-10 diagnosis codes can point to potential misuse: “An otherwise healthy adolescent female, for instance, who has a CPT code for mastectomy and an ICD-10 diagnosis code for an endocrine disorder, would arouse suspicion.”

While a patient’s medical record remains the only definite way to determine a treatment, the analysis and directives from various medical centers point toward potential misuse of these diagnostic codes.

“Medical diagnosis codes are being subverted by gender ideologues to avoid proper reporting, hide their activism from scrutiny, and potentially commit fraud. Groups like WPATH have publicly promoted the use of misleading diagnosis codes, and our report exposes how providers have financial incentives to do so,” Kurt Miceli, chief medical officer at Do No Harm, told National Review in a statement.

Dr. Ethan Haim, who previously exposed Texas Children’s Hospital’s secretive transgender procedures on minors, testified before Congress in April 2025 and warned lawmakers that providers were miscoding “gender-affirming” procedures, particularly in red states like Texas that have banned such procedures for minors.

During the hearing, Haim said insurance companies “don’t know that they’re getting defrauded.”

“This guide is essentially a template for how to commit medical fraud. We should all remember that this is something that people go to prison for. This is a major deal. They have entire departments and hospitals for this,” Haim told lawmakers of the guide produced by the Campaign for Southern Equality encouraging providers to miscode procedures.

Vanessa Sivadge, a former nurse at Texas Children’s Hospital, testified alongside Haim, describing discrepancies she noticed in paperwork. According to Sivadge, TCH was misdiagnosing patients and changing medical records to circumvent state law that banned these procedures.

Further, sex markers in diagnosis are not always accurate to a patient’s biological sex. A biological female, for example, could be coded as a male. If that “male” patient were prescribed testosterone, it may be appropriate if the patient is actually a biological male, but for a biological female, it may indicate “gender-affirming care.”

Do No Harm identified eight codes that may potentially hide gender transition procedures for minor patients: Hypopituitarism, other primary ovarian failure, testicular hypofunction, precocious puberty, other specified endocrine disorders, unspecified endocrine disorder, hormone replacement therapy, and hypertrophy of breast.

Medical groups have explicitly encouraged miscoding of these procedures, which at a minimum is avoiding official coding guidelines and ethical billing standards. At worst, it is masking gender-change procedures and treatments for minor-aged patients.

“By hiding transgender procedures behind codes meant for other conditions, providers are – at minimum – skirting guidelines and ethical standards,” Miceli said. “Our report highlights the need for greater regulatory oversight and medical review to ensure ICD-10 diagnosis codes are not being fraudulently misused.”

Editor’s Note: A previous version of this article suggested that Do No Harm had in its report stated that QueerDoc uses generic endocrine codes when filing insurance claims. The report notes that QueerDoc refers to that practice on its website, but it does not state that QueerDoc engages in that practice itself.