Editor’s note: This article discusses human reproductive anatomy.
Doctors are able to use fraudulent or misleading medical codes in order to hide “transgender” procedures from insurance companies and regulators, allowing them to potentially bypass state bans on genital mutilation and chemical castration, according to a new report.
The report from medical watchdog group Do No Harm shows how doctors are able to use medical codes claiming things like generic endocrine care as stand-ins for so-called “gender-affirming” interventions for children — both allowing the children to receive the irreversible drugs and procedures and ensuring doctors get paid for doing so. It also details how pro-mutilation groups like the World Professional Association for Transgender Health (WPATH) allegedly encourage doctors to do so.
“Medical diagnosis codes are being subverted by gender ideologues to avoid proper reporting, hide their activism from scrutiny, and enable potentially fraudulent billing practices. Groups like WPATH have publicly promoted the use of misleading diagnosis codes, and our report exposes how providers have financial incentives to do so,” stated Kurt Miceli, chief medical officer at Do No Harm and author of the report. “By hiding transgender procedures behind codes meant for other conditions, providers are — at minimum — skirting guidelines and ethical standards. Our report highlights the need for greater regulatory oversight and medical review to ensure ICD-10 diagnosis codes are not being fraudulently misused.”
Health care providers use ICD-10-CM (International Classification of Diseases) diagnosis codes to designate diagnoses and injuries for purposes of medical billing and data reporting. These codes allow Centers for Disease Control and Prevention (CDC) personnel to see how widespread certain illnesses are across the country, for example.
Medical professionals are supposed to “code to the highest level of specificity when supported by the medical record documentation,” according to the ICD-10-CM Official Guidelines for Coding and Reporting.
The fraudulent or misleading use of medical codes is something on the radar of the Department of Health and Human Services (HHS), as The Federalist reported. But despite an impending federal ban, along with numerous state bans, on health care providers and insurance companies using Medicaid funding to cover interventions like opposite-sex hormones and unnecessary mastectomies for children, some doctors may still be able to get away with it.
The report points to multiple pieces of evidence that doctors are using misleading or fraudulent coding in order to bypass protections that would prevent children from undergoing the interventions. Miceli uses a prescription fulfillment database for pharmacies as well as a database for medical claims that includes office visits. Then, with the National Provider Identifier (NPI), he attempts to establish a correlation between a prescription filled and an office visit, using the timeframe between the two data points to have “higher confidence in the association.”
“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,” the report states, noting that some of the data can be skewed because even sex markers in medical claims “cannot always be trusted” because “females may be coded as males and vice versa.” F64 ICD-10 codes cover “gender identity disorders.”
A surgical code coupled with an ICD-10 diagnosis code could also indicate cause for concern, the report states: “An otherwise healthy adolescent female, for instance, who has a CPT code for mastectomy and an ICD-10 diagnosis code for an endocrine disorder would arouse suspicion.”
The report identifies eight codes that may be the most likely to hide child “transition” interventions from insurers and regulators, including hypopituitarism, other primary ovarian failure, testicular hypofunction, precocious puberty, other specified endocrine disorders, unspecified endocrine disorder, hormone replacement therapy, and hypertrophy of breast.
Concern about doctors misusing the coding system to hide mutilation — and getting paid to do so — is not theoretical. Many major medical groups that advocate for and are otherwise involved in child mutilation have publicly voiced their intent to mislead.
According to the report, 2021 training materials from WPATH “endorsed the application of endocrine-related ICD-10 diagnosis codes for sex change treatments and insurance reimbursement.”
The Campaign for Southern Equality published a list of “insurance coding alternatives for trans healthcare,” which the report notes encouraged “the use of these misleading codes to avoid scrutiny and obfuscate sex-denying medical interventions.”
The publication provided the following commentary:
Some coverage is categorically excluded because they are viewed as cosmetic (i.e. breast augmentation, body contouring, facial feminization procedures) — generally speaking, these are hard to appeal and clearly delineate why they are medically necessary to meet the insurer’s standards. Some “subprocedures” are also not covered, even if they main procedure is covered (i.e. double mastectomy is covered for transgender men, but not nipple reconstruction; phalloplasty may be covered, but the testicular implants are not, often citing cosmetic purposes) — when this occurs, the service is easier to appeal, because most of these procedures are available to cisgender people, and the case can be made that the “cosmetic ruling” is being applied to trans people for the sake of denying care (i.e. sex discrimination).
The guide has apparently been removed from public view since March 2025, just after the Trump administration came into the White House.
However, Planned Parenthood of Southeastern Pennsylvania “explicitly states that it uses endocrine disorder codes ‘in order to meet the needs of most insurance companies and patients’ and only ‘occasionally’ uses gender identity disorder codes,” the report states, while QueerDoc “also notes on its website that ‘some providers use the code E34.9, Endocrine disorder, unspecified.’”
“Organizations such as WPATH, the Campaign for Southern Equality, Planned Parenthood, and QueerDoc have publicly promoted the use of non-F64 diagnosis codes in connection with so-called ‘gender-affirming care,’” the report states. “Payors and regulators — particularly in states that restrict such interventions for minors — should remain vigilant for any misuse of endocrine or other medical ICD-10 codes to obtain reimbursement for sex-rejecting procedures. This false portrayal of sex change interventions under the guise of a legitimate endocrine disorder, for example, lacks medical validity.”
Breccan F. Thies is the White House correspondent for The Federalist. He is a co-recipient of the 2025 Dao Prize for Excellence in Investigative Journalism. As an investigative journalist, he previously covered education and culture issues for the Washington Examiner and Breitbart News. He holds a degree from the University of Virginia and is a 2022 Claremont Institute Publius Fellow. You can follow him on X: @BreccanFThies.
