A report released Aug. 13 by the Department of Health and Human Services (HHS) has shined a light on alleged fraud by health providers who performed pediatric gender procedures.
The report, titled “Wolves in White Coats: How Doctors and Hospitals Pushed and Profited from the Fraud of ‘Gender Medicine’,” examined the actions and motives of 225 healthcare institutions and found they allegedly put profits and gender ideology ahead of patient needs.
Here are five key takeaways from that study.
HHS Alleges Insurance Coding Fraud
The HHS report laid out an alleged pattern of deception, encouraged by groups promoting gender procedures in children, where hospitals and healthcare providers utilized incorrect insurance codes to ensure they got paid.
Rather than use already-existing, specific codes related to gender identity disorders, HHS alleged they used what the study called “proxy diagnosis codes” that were vague, or outright false.
One common diagnosis was “endocrine disorder—unspecified,” which allowed doctors to bill for cross-sex hormones. HHS data showed that between 2015 and 2025, more than $42 million was billed to insurance companies under the unspecified disorder diagnosis.
A 2023 study by the University of Iowa Hospitals and Clinics found that out of 1,480 patients diagnosed with unspecified endocrine disorder, only 71 actually had such an illness. An analysis by the Manhattan Institute also found a 30 percent rise in such diagnoses between 2020 and 2022, HHS said.
Another common miscoding was for “precocious puberty,” which allowed the doctors to prescribe and bill insurers for puberty blockers. The study found that between 2015 and 2025, insurers were billed more than $11 million under this diagnosis for patients aged 13 to 17.
But that can’t be accurate, the report said, because 13 to 17 is the natural age for puberty.
Advocates Encouraged ‘Alternative Diagnosis Codes’
The World Professional Association of Transgender Health, Planned Parenthood, and other groups encouraged healthcare providers to use “alternative diagnosis codes” not related to gender dysphoria, the HHS report stated.
The Epoch Times reached out to these organizations for comment.
In one instance, a Harvard-affiliated gender clinic called Fenway Health advocated using “more vague” diagnosis codes, but also warned that using inaccurate coding is illegal.
Another organization, the Campaign for Southern Equality, put together a toolkit called “Insurance Coding Alternatives For Trans Healthcare” that outlined workarounds for patients with gender dysphoria.
Most insurers exclude gender procedures unless state law requires coverage, the document states. The toolkit shows which coding is frequently rejected by insurers, and which commonly accepted codes to use instead.
If the insurer denies coverage, the toolkit suggests appealing repeatedly. After the third appeal, the case “goes to an outside agency, and is often accepted.”
For example, a patient can claim orchialgia—persistent pain in the testicles—to justify surgical castration, according to the report.
“How do you do a mastectomy, but then bill an insurance company and not raise any red flags? … You bill it as breast reduction instead of a mastectomy,” said Dr. Eithan Haim, an author of the report.
“This guide is essentially a template for how to commit medical fraud. We should all remember that this is something that people go to prison for. This is a major deal.”
In 2024, Haim was indicted by the DOJ for allegedly exposing private information on patients after he accused a Texas hospital of secretly providing gender surgeries on minors in violation of state law. His case was dismissed with prejudice the next year.
Lifelong ‘Captive Patients’ and Revenue
So-called gender affirming care is lucrative as the “captive patients,” as the report called them, require continual medical maintenance that can last decades—or a lifetime.
“You take a little girl and put her on testosterone, or a little boy and put them on estrogen. Well, they’re going to be on that forever and ever, right?” Assistant HHS Secretary Adm. Brian Christine said in an interview with NTD, The Epoch Times’ sister media outlet.
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