CALL TO ACTION: Tell the FTC: Hands Off Gender-Affirming Care
The Federal Trade Commission (FTC) has launched an alarming Request for Information (RFI) to attack the field of gender-affirming care—a safe, effective, and medically necessary practice grounded in decades of research and clinical expertise—as an “unfair and deceptive practice.”
The FTC’s actions are not grounded in evidence and are a distortion of the agency’s mission to protect the public from actual deceptive practices. Instead, they reflect a deep-seated bias against transgender, gender-diverse, and intersex people.

What’s Happening?
The Federal Trade Commission (FTC) has launched an alarming “public inquiry” to attack the field of transition-related healthcare (gender-affirming care)—a safe, effective, and medically necessary practice grounded in decades of research and clinical expertise—as an “unfair and deceptive practice”.
We are calling on our community, trans people and our allies, to take action in support of the health care that is vital for our lives. The FTC is accepting public comments via Request for Information (RFI) until September 26.
Under Sections 5 and 12 of the Federal Trade Commission Act, the FTC has the authority to launch investigations into misleading, unfair, and deceptive trade practices and issue enforcement orders based on their findings, whenever they deem necessary and appropriate. RFIs such as this are likely intended to inform who they investigate and how. This authority extends to the ability to investigate and issue enforcement orders against those marketing and advertising various health products.
Why Does it Matter?
The Trump administration has continued to push false narratives about the transgender community. The FTC’s RFI is their latest effort to discredit our essential health care. Gender-affirming care is a safe, effective, and medically necessary field of medicine grounded in decades of research and clinical expertise. The provision of this healthcare to trans youth is overseen by well-trained clinicians utilizing staged and evidence-based clinical guidelines, that prioritize informed consent and open communication between providers, patients, and their families. For trans people, this care can be lifesaving.
This RFI will also impact intersex adolescents and adults whose healthcare needs significantly overlap with gender-affirming care, and whose identities have also previously been attacked by this administration. Adolescent and adult patients with intersex variations face similar consequences as they often depend on these same medical providers, who treat transgender patients, when seeking care.
The FTC’s actions are not grounded in evidence and distort the agency’s mission to protect the public from actual deceptive practices. Instead, they reflect a deep-seated bias against transgender, gender-diverse, and intersex people. The FTC should focus on stopping real consumer harm—not undermining trusted medical care that saves lives.
What Can You Do?
The FTC has opened a 60-day public comment portal—and your action and your story are urgently needed. This is a critical opportunity to submit your public comments in support of gender-affirming care for adolescents.
Read below for special instructions on how to submit your comment, what to include, and what not to include. Find a template from A4TE to write your comment here.
What You Need to Know Before You Submit
This portal will enable Advocates for Trans Equality to submit your story, on your behalf. This ensures that your submission is not traceable back to the computer or device you used to submit your comment. This “air gap” is a protective measure for our community and our allies. Because Advocates for Trans Equality is submitting your comment on your behalf, you may not notice your comment in the portal right away. We commit to submitting comments by the RFI’s deadline, September 26. Antagonistic, hateful, and threatening comments submitted through this portal will be omitted. If for any reason we encounter difficulty in submitting your comment, we will make every effort to contact you to resolve the issue. We will also retain a copy of your comment securely in our internal records.
Remember Your Audience
We encourage all submitting parties to consider the nature of the actions described in their comments, related to the FTC’s hostile framing of gender-diversity and the provision of gender-affirming care. Given this hostility, the information that you provide should be measured, free of identifying information, and provided in such a manner as to not put yourself or others at risk.
This portal will enable you to submit to the FTC Request for Information (RFI) with a reduced risk of identification than you may have if you were to make your submission directly to the Federal Regulations Portal.
As you draft your comment, depending on your experiences with and relationship to transition-related healthcare, also called “gender-affirming care”, there are certain pieces of information you should consider sharing as well as pieces of information you should highly consider omitting.
Legal Disclaimer: As an intermediary party in your submission, Advocates for Trans Equality and Advocates for Trans Equality Action Fund take no responsibility for comments, statements, or actions described in your submission; nor does our delivery of your submission to the FTC represent an endorsement of said statements, attitudes, or actions.
By submitting text to this portal, you are consenting to having the exact, unedited text of your comment uploaded to the FTC’s Regulations.gov comment portal. If you include your name or other identifiable information, we will include this in your submitted comment.
BEFORE YOU SUBMIT A COMMENT, PLEASE READ:
Tips for your Safety
All submitting individuals should read the following guidelines closely to minimize community risk. Don’t see yourself listed below? That’s okay! You can still submit a comment. Reviewing the information below can still help you craft a comment that is safe and helpful!Expand allCollapse all
All Submitting Individuals
These comments will be viewable by the general public as well as this administration’s Federal Trade Commission. Accordingly, we highly recommend that regardless of your experiences, you withhold and avoid disclosing any identifying information. This includes:
- Your full name (consider using a pseudonym);
- Your date of birth, social security number, or other identification numbers;
- The name of your patients, children, or medical providers;
- The state you currently reside in and where transition-related care was received;
- Your address;
- The exact location, including the name of the clinic or hospital, where you or your child received care;
- Where you work
Again, all submitting parties should withhold the information above, as well as any similar identifying information.
Parents and Caregivers of Trans and Gender-Diverse Youth
Great Information to Share
This RFI is seeking information regarding your experiences accessing and navigating the clinical provision of transition-related healthcare with your minor child. The RFI is looking for information from the public regarding how that care was described to you and your child, as well as the conditions under which it was provided. In that regard the following types of information are excellent to share in your submission:
- Any barriers to accessing this care;
- The ways in which potential adverse effects of various treatments were described to you;
- The materials you received about this care;
- The depth of the discussion and the number of appointments that pre-dated the first treatment;
- How your child was diagnostically assessed;
- Your oversight of the treatment process;
- The strength of your child’s understanding of their gender identity;
- The psychological and mental health support that your child received both before and alongside this care;
- The positive effects and benefits of this care for your child;
- Your provider’s professionalism;
- The deliberate and gradual nature of how this care was provided;
- The clinical guidelines that your provider utilized;
- Your role in supporting your child in their transition;
- The extensive nature of the counseling you and your family received regarding this care.
What to be Cautious of Sharing
This administration, including the FTC, has demonstrated a hostility towards gender-diversity itself as well as the field of transition-related care. Accordingly, the information that you provide has a high potential to be taken out of context and distorted. Within the context of the FTC’s authority to investigate this healthcare, parents/caregivers are likely to be considered “consumers”, much like patients. This, however, is an informed guess and we encourage parents/caregivers to exercise caution with what they communicate in their submission. Some considerations:
- Avoid characterizing experiences as quick or brief;
- Avoid downplaying providers’ disclosures of potential adverse effects;
- Do not share the names of your providers, nor any identifying information about them;
- Be cautious regarding how you describe the informed consent process.
Medical and Behavioral Health Professionals
Great Information to Share
This RFI is seeking information regarding how adolescents and their families accessed transition-related healthcare. As healthcare professionals you play an integral role in this process, ensuring that transgender adolescents can access the potentially lifesaving medical care that they need to thrive and lived authentic and fulfilling lives. Your role in this care is also under particular scrutiny by the RFI, and as a result you should carefully consider the information you share and how you share it. We have provided a list of recommended Do’s and Do Not’s for you to take into consideration while your draft your comment
DO:
- Keep your submission HIPAA compliant.
- Do ensure all information about you and your patients is de-identified.
- Do share general, high-level descriptions of your experience and expertise.
- For example: “As a pediatric endocrinologist who has treated gender-diverse patients for over 23 years…” or “I am a licensed psychotherapist who has treated over 2,000 adolescents during my career…”.
- Describe the depth and length of conversations with patients and their parents in equal measure and weight.
- Describe the depth and length of your discussions with families regarding the benefits, common adverse effects, and potential adverse effects of treatment.
- Describe the procedures related to policy development within professional medical and behavioral health.
- Describe the rigor of the informed consent process.
- Describe the evidence-based nature of the care you provide.
- Feel free to share articles from peer-reviewed journals.
- Describe the materials you provide to parents and patients.
- Describe the benefits of treatment that you’ve witnessed for patients and their families.
- Describe the staged and intentional nature of your clinical approach.
- Describe the length, rigor, and depth of your professional training.
- Present evidence-based, peer-reviewed statistics and information regarding the patient population.
- Keep information focused on the patient/family relationships, to the exclusion of administrative procedures and practices.
DO NOT:
- Provide information about the state you practice medicine in.
- Provide identifying information about your practice or your patients.
- Provide your name.
- Provide the exact name of the institutions where you were trained.
- Provide the name of your practice, hospital, or clinic where you practice.
- Provide license numbers.
- Cite op-eds as substantiating evidence regarding this care.
- Downplay your expertise.
Adults Who Received Care as a Minor Adolescent
You are likely to be considered a “consumer” by the FTC, you should still carefully consider the information you share in your comment, as well as how you share it.
Great Information to Share
- Any barriers to accessing this care;
- The ways in which potential adverse effects of various treatments were described to you and your parents;
- Your ability to understand and consent to care;
- The materials you received about this care;
- The depth of the discussion and the number of appointments that pre-dated the first treatment;
- The depth and strength of your understanding of your gender-identity prior to initiating care;
- The psychological and mental health support that you received alongside this care;
- The positive effects and benefits of this care;
- Your provider’s professionalism;
- The staged nature of how this care was provided;
- The clinical guidelines that your provider utilized;
- Your parents’ role in supporting your child in their transition;
- The extensive nature of the counseling you and your family received regarding this care.
What to be Cautious of Sharing
- Avoid characterizing experiences as quick or brief;
- Avoid downplaying providers’ disclosures of potential adverse effects;
- Do not share the names of your providers, nor any identifying information about them;
- Be cautious regarding how you describe the informed consent process.


