Woodhull Response to Federal Trade Commission Public Inquiry on Gender-Affirming Healthcare
September 26, 2025
Woodhull Freedom Foundation is a national organization dedicated to defending and protecting sexual freedom as a fundamental human right. We are responding to the Federal Trade Commission’s (FTC) Public Inquiry on Gender-Affirming Healthcare because we are deeply concerned by the harmful, misleading, and biased premise underpinning this effort. This request for information demonstrates that the FTC is no longer an independent agency meant to protect consumers from deceptive and fraudulent practices. Instead, the FTC has become a tool of President Trump’s administration to further their devastating assault on transgender and gender-diverse communities across the country. We therefore urge the FTC to abandon this current investigatory effort regarding gender-affirming care.
While gender-affirming care has been linked in the public discourse as solely relating to medical care for transgender individuals, it is a much more expansive field of medicine, which may include any of the following procedures for cisgender, transgender, intersex, non-binary, and gender-diverse individuals:
- Reproductive and gynecological care such as fertility treatment or pelvic floor therapy following childbirth or prostate surgery.
- Surgical and aesthetic procedures such as hair restoration or removal, chest or breast reconstruction or reduction surgery to reduce pain or following cancer.
- Hormonal treatments such as hormone therapy for perimenopause or menopause, or testosterone or estrogen therapy for conditions such as hypogonadism or premature ovarian insufficiency.
Yet, the FTC’s request for public comment and related press release make it clear that the intentions of this public inquiry are not to improve consumer access or experiences with gender-affirming care but to target transgender individuals, particularly youth. The ultimate goal being to eradicate access to this lifesaving medical treatment for transgender individuals not based on science but based on biased gender-essentialist ideology.
Gender-affirming care for transgender and gender-diverse individuals is a longstanding and evidence-based field of medicine which includes a safe, effective, and medically necessary set of treatments grounded in decades of rigorous clinical standards. This medical care is already regulated by a diverse range of professional associations, licensing boards, and clinical practice guidelines.
For many years, Woodhull has defended transgender people’s access to this medical care as it is fundamental to protecting their right to health. In this comment we attach our organization’s prior publications on the subject as evidence of the critical role gender-affirming care plays in ensuring the health, safety, and rights of transgender individuals. We also attach the report Health and Wellbeing: A report of the 2022 U.S. Transgender Survey, which provides crucial findings on the centrality of gender-affirming care for the health and wellbeing of transgender individuals.
This care is prescribed by highly trained clinicians who undergo nearly a decade of professional training in order to serve the healthcare needs of their patients. These professionals administer these treatments in a staged manner, in keeping with evidence-based clinical guidelines that emphasize informed consent, transparency, and shared decision-making with patients and their families. These standards include clear discussions and disclosure of potential adverse effects and benefits, ensuring that every individual and their caregivers are empowered with accurate, honest information regarding the treatments being prescribed.
The FTC should not allow political or ideological pressure to distort its regulatory role. Its focus should remain on real threats to public health and consumer safety, not on fueling stigmas or restricting access to essential, affirming care.
Woodhull calls on the FTC to stop this misguided scrutiny and instead uphold its responsibility to protect, not harm, the health and well-being of all people—especially those most at risk of discrimination and marginalization.
We have included a PDF copy of this comment as an attachment.
Sincerely,
Ricci Joy Levy
President & CEO
Woodhull Freedom Foundation
The Woodhull comment to the FTC is available here.