Published September 26, 2025
On September 26, 2025, EPPC Scholars Eric Kniffin and Mary Hasson submitted a public comment in response to the Federal Trade Commission’s request for information (RFI) regarding “gender-affirming care” for minors.
The FTC’s RFI sought information to help the Commission “better understand how consumers may have been exposed to false or unsupported claims about ‘gender-affirming care’ (GAC), especially as it relates to minors, and to gauge the harms consumers may be experiencing.” The FTC is looking to see whether medical professionals or others may have violated the FTC Act by failing to disclose material risks associated with sex-rejecting procedures or by making false or unsubstantiated claims about the benefits or effectiveness of sex-rejecting procedures.
The scholars’ comment begins by thanking the FTC and the Trump administration more broadly for advancing policies that reflect a true understanding of the nature of the human person, something at the heart of EPPC’s mission. The comment also urges the FTC and Trump administration to adopt the term “sex-rejecting procedures” to replace the term “gender-affirming care,” a term Justice Thomas recently said was a “sanitized description” that “obscures the nature of the medical interventions at issue.” Kniffin and Hasson point to the white paper they published in May with EPPC Scholar Rachel N. Morrison that argues for the use of the term “sex-rejecting procedures.”
The comment urges the FTC to investigate whether “gender medicine” advocates and practitioners have broken the law through false and misleading statements about how sex-rejecting procedures can impair fertility or even cause sterility. The scholars note it is unreasonable to think minors can give consent to losing their fertility and note that “fertility preservation” is unethical and rarely used.
It also attaches over ninety pages of documents from gender clinics documenting their incomplete disclosures and efforts to obtain minors’ informed consent for sex-rejecting procedures.
Finally, the comment thanks the FTC for its concern and urges it to use the authority it has been delegated by Congress and President Trump to protect Americans from gender ideology.
Other legal, medical, religious, and policy organizations also submitted comments in response to the RFI, including:
- Advancing American Freedom
- Alliance Defending Freedom
- American College of Pediatricians
- Center for Bioethics & Culture Network
- Christian Medical & Dental Associations
- Concerned Women for America
- National Catholic Bioethics Center, Catholic Medical Association, Catholic Bar Association, and National Association of Catholic Nurses, USA
- Partners for Ethical Care
Eric Kniffin is a fellow at the Ethics and Public Policy Center, where he works on a range of initiatives to protect and strengthen religious liberty as part of EPPC’s Administrative State Accountability Project.
