Peter Sprigg, FRC’s Senior Fellow for Policy Studies, submitted the following letter on May 12, 2020, to the California Legislature in opposition to AB 2218, the “Transgender Wellness and Equity Fund.”
Dear California Legislators:
I am writing to urge that you oppose Assembly Bill 2218, which would establish a “Transgender Wellness and Equity Fund” with an appropriation of $15 million. I am writing on behalf of Family Research Council (FRC), a national non-profit public policy organization representing tens of thousands of Californians, and whose issue portfolio includes human sexuality.
In particular, we believe that it is inappropriate to provide taxpayer dollars
to a hospital, health care clinic, or other medical provider that currently provides gender-affirming health care services, such as hormone therapy or gender reassignment surgery, to continue providing those services, or to a hospital, health care clinic, or other medical provider that will establish a program that offers gender-affirming health care services . . .
No “hormone therapy” (neither puberty-blocking hormones nor cross-sex hormones) has been approved by the U.S. Food and Drug Administration (FDA) for the purposes of facilitating gender transition. Fenway Health, which serves the LGBT community in Boston, writes that “no medications or other treatments are currently approved by the Food and Drug Administration (FDA) for the purposes of gender alteration and affirmation.” A 2018 article in the journal Transgender Health reiterated that “there are no medications or other treatments that are FDA-approved for the purpose of gender affirmation.” And the American Medical Association’s Council on Science and Public Health reported that “steroidal hormones,” “GnRH analogs” (puberty blockers) and “antiandrogens” are all used “off-label” for “gender re-affirming therapy”—because their use “lacks scientific evidence.” While it is not illegal to use drugs “off-label” in certain instances, the lack of proof that using these hormones for gender transition is safe and effective is a strong argument against the state funding these largely experimental treatments.
Similarly, evidence does not support the assertion that gender reassignment surgery is “medically necessary.” In 2016, the Centers for Medicare & Medicaid Services under the U.S. Department of Health and Human Services (CMS) declined to issue a new “national coverage determination” (NCD) that would mandate coverage for such surgery under Medicare, declaring that “there is not enough high quality evidence to determine whether gender reassignment surgery improves health outcomes.” CMS examined 33 studies, but found that all had “potential methodological flaws,” and that “[o]verall, the quality and strength of evidence were low.”
Even the evidence that is available does not demonstrate that gender reassignment surgery is effective at achieving its fundamental goal—improving the long-term mental health of individuals. Patients in the best studies “did not demonstrate clinically significant changes” after surgery. One of the strongest studies, out of Sweden, showed a suicide rate among post-surgical transgender patients that was 19 times that of the general population.
In addition to directly funding procedures of questionable medical value (as well as “guided meditation” and “dancing, painting, and writing classes”), this bill would also fund programming that essentially amounts to ideological indoctrination, in the form of “trans-inclusive best practices” and the creation of “educational materials” and “capacity building training.”
It also seems ironic that the sponsors of this legislation, who I presume would support laws to prohibit “discrimination” on the basis of “gender identity,” are actually mandating such discrimination by giving favored treatment to organizations that meet a numerical quota of officers, board members, or a fiscal sponsor who themselves “identify as TGI” (“transgender, gender nonconforming, or intersex”).
Finally, it seems inconceivable that during a crisis caused by a global pandemic, with tax revenues shrinking and emergency expenditures rising, the California Legislature would even consider investing time or money in a program that would have to be considered a luxury even in normal times, and even if it were worthwhile (which, for the reasons cited above, I believe it is not). When, at this writing, nearly 70,000 Californians have become infected with the novel coronavirus and nearly 2,800 have lost their lives, it would reflect misplaced priorities to be appropriating money to support the programs listed above.
I urge you to oppose AB 2218.
Senior Fellow for Policy Studies
Family Research Council