Published November 14, 2025
On November 14, 2025, EPPC Scholars Mary Rice Hasson, Rachel N. Morrison, and Eric Kniffin submitted a public comment to the Department of Health and Human Services’ (HHS) ICD-10 Coordination and Maintenance Committee in support of a proposal to add medical diagnostic codes to account for the medical needs of those who previously underwent, but then discontinued, sex-rejecting social, hormonal, or surgical interventions. These individuals are sometimes referred to as “detransitioners.”
In their comment, the scholars explained the historical context and need for medical codes:
There is no systematic way of tracking how many individuals fall into this category or of describing their specific medical needs. There is no recognized label for their condition or its characteristic injuries, symptoms, and outcomes. There are no protocols to guide physicians in ways to help these vulnerable patients reverse the damage done by de-masculinizing and de-feminizing interventions….
Without appropriate diagnostic codes to indicate the etiology of their condition, and its current manifestation, these patients—and their injuries—are invisible to the healthcare system. They are seeking to recover their health and to alleviate suffering that is a direct result of a zealous, ideology-driven experiment, unsupported by reliable medical evidence.
As the scholars wrote: “The Committee and HHS should, as a matter of justice, do what it can to help provide the structural framework, including appropriate medical codes, that will permit the healthcare system to respond effectively and systematically to their needs.”
The scholars also pointed out that adopting medical codes, such as the ones proposed, “aligns with President Trump’s policy priorities to protect children from ‘chemical and surgical mutilation,’ combat gender ideology extremism, restore biological truth to the federal government, and Make America Healthy Again (MAHA).”
Other organizations also submitted comments in support of the proposed codes, including:
- Catholic Medical Association
- Genspect
- National Association of Catholic Nurses
- The National Catholic Bioethics Center
- National Catholic Partnership on Disability
- Partners for Ethical Care
Rachel N. Morrison is a Fellow at the Ethics and Public Policy Center, where she directs EPPC’s Administrative State Accountability Project, which advocates for an authentic understanding of the human person in the drafting, implementation, and rollback of government regulations.
