The board has submitted this comment with respect to two proposed federal rules that would restrict funding for medical procedures to disguise the sex of minors:
- CMS-2451-P, prohibiting Federal Medicaid and Children’s Health Insurance Program (CHIP) funding for sex-rejecting procedures on minors.
- CMS-3481-P, adding a Hospital Condition of Participation that bars Medicare- and Medicaid-participating hospitals from performing sex-rejecting on children under 18.

Women’s Declaration International (WDI) is a global, nonpartisan group of volunteer women dedicated to protecting women’s sex-based rights, based on the Declaration on Women’s Sex-Based Rights (“the Declaration”). Women’s Declaration International USA, Inc. (WDI USA) is its U.S. chapter. Our opposition to this bill is based on Article 9 of the Declaration, which reaffirms the need for the protection of the rights of the child, specifically opposing harmful medical procedures intended to disguise sex.
It has been well established that the vast majority of children who experience discomfort with their sex will outgrow those feelings if allowed to go through puberty. Most of these children tend to become lesbian or gay adults. A 2021 study using the largest sample to date of boys clinic-referred for gender dysphoria showed that 88% desisted by their early 20s; this is consistent with the outcomes of previous studies on desistance. The health and well-being of children are best served by grounding them in the reality of their sexed bodies, and not by supporting pharmaceutical and surgical interventions on young people’s healthy bodies that will affect them irreversibly for life.
The adverse effects of Lupron, a so-called “puberty blocker,” include seizures, bone loss, and mood disorders. Adverse effects of cross-sex hormones include heart disease, cardiovascular damage, and deep vein clots. The US Department of Health and Human Services has found that there is no credible evidence showing a link between such medical interventions and a reduction in suicidal ideation, and the leaked WPATH files reveal the casual and cynical malpractice behind the widespread use of medical procedures aimed at disguising people’s sex.
WDI USA has authored a model bill that would ban such procedures in minors, in which we use the term ‘procedures to disguise sex’ rather than ‘sex-rejecting procedures.’ Our terminology is more accurate because in fact no human is able in reality to reject his or her sex. Nevertheless, WDI USA strongly supports this rule.
The WDI USA board
Elizabeth Chesak
Lauren Levey
Katherine Kinney
Lorraine Nowlin
Holly Stewart
