Do No Harm Files HRSA Comment on Children’s Teaching Hospitals and Sex-Rejecting Procedures
Earlier today, Do No Harm submitted an official comment in support of a Health Resources and Services Administration (HRSA) proposal that would help the government track the extent to which it is funding pediatric sex-rejecting ideology.
Though complicated, the proposed change deserves the backing of all who wish to protect children from damaging and unproven medical interventions.
The Children’s Hospitals Graduate Medical Education (CHGME) Payment Program exists to provide federal funding to freestanding children’s teaching hospitals.
Such institutions usually treat fewer Medicare patients than do general teaching hospitals and consequently received less federal support until the creation of the CHGME Payment Program in 1999.
By statute, institutional grant recipients of CHGME Payment Program funding must provide annual data about their operations to the federal government. HRSA’s new proposal would add to the required data collection an additional dropdown option for three questions.
Specifically, the revised data-collection instrument would
- add “Sex Rejecting Procedures and Services for Minors” as a dropdown option on the Program Curriculum Changes form;
- add “Individuals Receiving Training on Sex Rejecting Procedures and Services for Minors” as a dropdown option on the Individual Characteristics form; and
- add “This Site Offers Sex Rejecting Procedures and Services for Minors” as a dropdown option on the Experiential Training Sites form.
In short, the government would gain a clearer sense of how taxpayer money is being used to train physicians in pediatric “gender-affirming care.”
HRSA asks public commenters to address “the necessity and utility of the proposed information collection for the proper performance of the agency’s functions.”
The proposal meets that standard for three reasons.
First, sex-rejecting procedures have been performed on minors at scale in the very hospitals the CHGME Payment Program funds. A Do No Harm analysis of the period 2019–2023 identified 12 hospitals as the worst-offending children’s hospitals promoting sex-rejecting procedures to minors. Every one of those 12 children’s hospitals was a CHGME Payment Program grantee.
Second, the federal government has no reliable means of collecting this information at present, and this collection supplies one, thus allowing policymakers responsible for a training program of more than $370 million a year to know whether the program is preparing physicians to deliver interventions with “very uncertain” benefits and substantial evidence of harm.
Third, given the current state of the evidence, whether a federally funded training program teaches these procedures speaks directly to the quality of the education the program provides. Training residents and fellows to deliver interventions with “very uncertain” benefits and “less uncertain” harms is not high-quality graduate medical education.
We urge our members to file comments of their own, particularly (but not exclusively) if they have firsthand experience of witnessing or engaging with gender ideology at a children’s teaching hospital funded by the CHGME Payment Program and believe that ideological intrusion to be indicative of poor quality.
Public comments needn’t be formal, lengthy, or formatted in a specific way. A few sentences will do.
Please join us in telling the HRSA that the federal government should ask CHGME Payment Program grant recipients for the information described above.
Email [email protected] to make a public comment of your own. (Be sure to mention the title “Bureau of Health Workforce Performance Data Collection, OMB No. 0906-0086-Revision.”) Deadline: Nov. 9.
Or click here, or scroll down, to read Do No Harm’s full comment.

