In the wake of the Supreme Court's Dobbs ruling that ended federal abortion rights, abortion providers easily circumvented red-state restrictions by mailing pills that starve and suffocate a fetus directly to women or potentially partners who could secretly drug them, a practice now temporarily reinstated by Supreme Court Justice Samuel Alito.

Providers of so-called gender-affirming care for young people are doing the same with testosterone, "unopposed" estrogen, puberty blockers, anti-androgens and dihydrotestosterone (DHT) blockers, circumventing state Medicaid restrictions and lying to insurance companies by misrepresenting the purpose of the treatments, according to a new report.

The World Professional Association for Transgender Health, Campaign for Southern Equality, Planned Parenthood and QueerDoc have "publicly promoted the use of non-F64 diagnosis codes" – those not intended to code gender-identity disorders – to perform "sex-denying" procedures on children, medical advocacy group Do No Harm alleges.

"By framing these practices under conventional endocrinology or other non-F64 medical diagnoses, providers, at a minimum, circumvent official coding guidelines and ethical billing standards" if not commit insurance fraud and violate state laws restricting Medicaid funding for pediatric medicalized gender transitions or the procedures themselves, the report says.

None of the groups flagged by Do No Harm answered Just the News queries for their response to the allegations, which are backed by live and archived versions of their own webpages. 

The Justice Department is seeking judicial relief to continue probing healthcare providers for evidence of such insurance billing fraud, "misrepresenting a patient’s sex in medical records" and fraudulently diagnosing gender dysphoria so insurers will cover off-label prescriptions of cross-sex hormones and puberty blockers.

The department asked the 4th U.S. Circuit Court of Appeals last week to overturn a lower court that quashed its July 2025 subpoena to Children's National Hospital, in Washington, D.C., which paused pharmaceutical gender transitions right after President Trump's executive order against such youth treatments and permanently ended them two months after the subpoena.

U.S. District Judge Julie Rubin, nominated by Democrat President Joe Biden, "misunderstood the legal standard and largely ignored the government’s explanation of relevance," while wrongly "relying on [her] assessment of the 'policy objective' of the administration," DOJ said.

Rubin, before her 2022 confirmation, faced interrogation on abortion and gender identity by then-Senate Judiciary Committee Ranking Republican Chuck Grassley.

DOJ is also trying to resurrect its subpoena for QueerDoc – a self-described 'Trans Online Doctor's Office' – that was quashed last fall by another Biden nominee, U.S. District Judge Jamal Whitehead, better known for ordering the administration to admit 12,000 refugees a year ago. 

The 9th Circuit heard oral argument in March but has not ruled yet. DOJ's January reply brief argued Whitehead wrongly quashed the subpoena "based on an ostensible improper subjective purpose," a novel "heightened standard" which he should have at least let the government try to satisfy." 

How to spot a deceptive coding needle in a multi-database haystack

"The rise of the child transgender industry over the past decade has relied, in no small part, on the financial incentives for physicians and hospitals to perform sex-denying medical interventions," which "offer a potentially lucrative revenue source," says the report by Do No Harm Chief Medical Officer Kurt Miceli, also a Drexel University medical professor.

The "variable" insurance coverage for gender-affirming care and state restrictions on insurance coverage for, and availability of, pediatric gender transitions has prompted providers to misrepresent them as "routine endocrine care," for example, violating ICD-10 guidelines that require providers to code to the "highest level of specificity," the report states.

WPATH's 2021 training on its Standards of Care 7, then soon to be replaced by the Biden administration-influenced SoC 8, show it endorsed "endocrine-related ICD-10 diagnosis codes" to hide gender transitions and get insurance reimbursement, while a since-removed CSE page listed 14 codes "commonly accepted" by insurance in lieu of oft-rejected F64.

Planned Parenthood of Southeastern Pennsylvania says it "typically" uses the "unspecified" endocrine disorder code E34.9 to get insurance companies on board, and "occasionally" F64 "if necessary." 

QueerDoc also recommends E34.9 for insurance claims because it "can sometimes be used for labs, prescriptions, and visits" but not for surgery, and tells patients to "talk to your provider" if they are worried about F64 appearing in their medical records.

Miceli also warned that Z codes, "used to document factors influencing health and prior historical health services, may be used to capture" instead of "contextualize" therapies such as hormone administration, which "effectively circumvent[s] official coding guidelines" by misrepresenting gender interventions as "routine endocrine care."

Three-quarters of the report is appendices covering medications associated with gender transitions, "Current Procedural Terminology" codes related to office visit codes and CPT codes used to obscure gender-affirming surgery, and J codes related to specific medications such as puberty blockers and injectable hormones.

The labyrinthine system for health insurance claims makes it easy to mask gender-affirming care as "legitimate medical" care, requiring the review and correlation of pharmacy and medical office visit databases, according to the report, which lists red flags.

A prescription claim for testosterone in an "adolescent female within 3 days of an office visit without an F64 ICD-10 diagnosis code for that visit would raise concerns of potential miscoding of the office visit claim," as would an "otherwise healthy adolescent female" with a mastectomy CPT code and ICD-10 diagnosis code for an endocrine disorder, it says.

Miceli warned that "sex markers in medical or pharmacy insurance claims data" can be suspect, but "longitudinal searches for codes associated with sex-specific conditions or diseases," such as conception, pregnancy and "organs that are not created during gender surgeries (i.e., uterus, ovaries, prostate)," can help identify deceptive sex markers.

Common codes that "raise suspicion" include those for pituitary hormone deficiency, "primary ovarian failure," "low testicular function in males" and especially precocious puberty, in which a spike in diagnoses in older children in the past decade suggests they were a cover for gender-affirming care, the report says.

Misrepresentations 'plastered all over the internet'

Do No Harm echoes concerns often raised by whistleblower surgeon Eithan Haim, prosecuted by the Biden administration for exposing Texas Children's Hospital's pediatric gender transitions in apparent violation of state law. 

Biden's DOJ tacitly admitted giving incorrect information to a grand jury via documentation contradicting TCH's claim that it ended the treatment for minors when the state banned it, but a President George W. Bush nominee still refused to let Haim see grand jury material. Trump's DOJ quickly dropped the case.

Contrary to Judge Rubin's conclusion that DOJ's investigation of Children's National lacked "legitimate investigative purpose," one of its doctors led a Journal of the Endocrine Society study that "flagged gender patients using the fake billing code" E34.9, Haim wrote on X, urging DOJ to note the evidence against Children's National is "plastered all over the internet."

Haim singled out another judge-quashed subpoena with evidence in plain sight, against Boston Children's, whose researcher contributed to a study of autoimmune diseases in transgender and "gender diverse" youth in Transgender Health. Boston Children's patients with gender dysphoria were identified by both F64 and E34.9 codes, the study said.

Addressing U.S. District Judge Myong Joun, yet another Biden nominee, Haim wrote "here is your answer" to the question of "why exactly the Government is trying to investigate" Boston Children's, pointing to the 2024 study.