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Three years after Oregon lawmakers passed a law requiring insurers to cover transgender medical services, state regulators have quietly delayed their efforts to ensure the law is making a difference for a group that’s long faced barriers to care.
The paused oversight stems from financial uncertainty facing Medicaid and the Trump administration’s intensifying attacks on gender-affirming care. The delay means an incomplete picture of whether the new law has shortened wait times or removed bureaucratic obstacles for transgender patients. It’s also a departure from the urgency officials and advocates directed to the high-profile law that supporters called life-saving.
Oregon’s efforts to protect gender-affirming care are being tested by a federal government actively hostile to it. Advocates for transgender people don’t agree on how the state should respond, but they worry gender-affirming care could become harder to come by in Oregon. State officials won’t know how many providers have been lost.
“This is the end game of instilling fear in people,” said Jenn Burleton, the Beaverton-based founder of the TransActive Gender Project, of regulators’ plans to not evaluate whether Oregon’s commercial and Medicaid insurers are meeting transgender patients’ needs.
Burleton said regulators’ decisions means lawmakers won’t have to account for the law’s effectiveness, and that they’re playing into the Trump administration’s attempt to disrupt access to gender-affirming care. Meanwhile, transgender patients are at risk of being “dropped and forgotten,” she said.
However, Basic Rights Oregon, the state’s leading LGBTQ+ advocacy group, supports the paused oversight out of concerns that tracking whether the law is working could make it easier for federal authorities to target providers and patients.
Since returning to office, President Donald Trump’s administration has taken a series of actions targeting medical care for transgender people, whose internal sense of their gender differs from their sex assigned at birth. The administration has focused on blocking adolescents’ access to gender-affirming care, moving to cut off federal funding while threatening providers with prosecution and sending subpoenas to clinics.
Oregon has lost providers, particularly in rural areas, because of the Trump administration “seeking out and weaponizing sensitive provider and patient information from the state to intimidate providers out of providing reproductive and gender affirming care,” according to a statement provided by Kyndall Mason, Basic Rights Oregon’s executive director.
“At a time when transgender and nonbinary people, their families and their providers are being targeted at the federal level, we support the state’s efforts to ensure Oregonians can continue to access medically necessary care across their lifespan without putting patients or providers at greater risk,” the group wrote in the statement.
A state report released last year points to gaps in medical care for transgender people. The report also found no comprehensive data on the availability of gender-affirming care in Oregon while anticipating demand to grow, particularly as other states restrict access to it.
There are 33,200 adult Oregonians who identify as transgender, according to the Williams Institute at the UCLA School of Law’s 2025 estimate. That’s a nearly 67 percent increase from the institute’s 2022 estimate.
The institute also estimated there are 9,000 transgender teenagers under 18 in Oregon, a near tripling from its last estimate that it attributed to improved data availability as well as changes to its methodology.
Gender-affirming care covers a wide range of treatments, including hormone therapies, hair electrolysis and facial feminization. For minors, doctors may prescribe medications to suppress puberty and prevent changes like breast development, menstruation, deepening voices and facial hair. Doctors might also prescribe hormone therapy. These treatments are broadly supported by major medical organizations.
Oregon lawmakers passed House Bill 2002 in 2023 to prevent commercial insurers from denying patients gender-affirming treatments that their health care providers deemed medically necessary.
The law puts the Department of Consumer and Business Services in charge of enforcement, directing it to examine all insurance carriers subject to the new requirements to ensure compliance by January 2027. The department was to report to lawmakers on its implementation of HB 2002 by Dec. 31.
Both would require regulators to collect “detailed carrier, provider and individual claims information” about gender-affirming care, Jason Horton, spokesperson for the department’s Division of Financial Regulation, wrote in an email.
“Given recent federal actions directed at people who provide and receive this care, we have reason to believe an exam by this date could put Oregonians’ private health information at risk,” he wrote. Regulators have also been focused on stabilizing the individual insurance market in response to strains from federal policy changes, he wrote.
He added that the work will continue when “it can be done confidently without putting patients and providers at risk.”
Meanwhile, HB 2002’s coverage requirements remain in effect and are enforced by regulators, he wrote.
Horton declined to elaborate on what private health information could be put at risk by federal actions.
Dr. Kara Connelly, a pediatric endocrinologist and medical director of the gender clinic at Oregon Health and Science University’s Doernbecher Gender Clinic, told a legislative panel earlier this year that the clinic has faced multiple death threats and seen providers doxed.
“The political and legal threats, in addition to fears about doxing, have had a chilling effect on individual providers and clinics,” she wrote.
As a result, other speciality clinics removed their websites entirely, causing confusion about what services are available, she wrote. Efforts by her team to improve access to gender-affirming care in central and eastern Oregon, as well as Willamette Valley have also been undone, she wrote.
Connelly’s testimony was in support of House Bill 4088, which Gov. Tina Kotek signed into law earlier this year. The law restricts the state’s cooperation with federal investigations or inquiries into legally protected reproductive or gender-affirming health care, among other provisions.
Horton did not respond to a question about whether the bill provides adequate protections.
The Oregon Health Authority has similarly dropped its earlier effort to ensure regional Medicaid insurers, known as coordinated care organizations, have enough gender-affirming care providers to meet their low-income members’ needs.
The effort began in 2024 under then-Director Sejal Hathi after an advisory committee warned that 160,000 trans people and families were leaving states that were restricting access to gender-affirming care. Hathi laid out her plan in a letter to the Oregon Health Policy Board, calling gender-affirming care a “critical factor for the safety and thriving” of trans and non-binary people.
Hathi, who stepped down in August, called for evaluating claims data on gender-affirming care services before directing coordinated care organizations to determine how many members required this care. The work was supposed to be concluded by early 2026.
In September, six months after this reporter sought public records related to the analysis Hathi ordered, the health authority said there were no responsive records.
The health authority had expected coordinated care organizations to share numbers on how many members require gender-affirming care by fall 2025, spokesperson Franny White wrote in an email.
But by then, challenges facing the Oregon Health Plan, the state’s version of Medicaid, eclipsed that work, according to White. Those challenges included financial instability facing coordinated care organizations and federal changes to Medicaid. Additionally, an insurer did not renew its contract for Lane County.
“In the coming months and as workloads permit, OHA will renew this data request and clarify that CCOs will be required to respond in full by a firm deadline,” she wrote.
The health authority held listening sessions to hear about transgender Oregonians’ health care needs, White wrote. Providers, advocates and community members told officials that “many patients must travel multiple hours because they don’t have a local provider they trust and wait months or even years for an appointment because demand for gender-affirming care exceeds available providers.”
Oregon was one of the first states to cover gender-affirming health services through its Medicaid program beginning in 2015.
None of Oregon’s coordinated care organizations agreed to speak on the record for this story.
Burleton said she’s heard from transgender people that the Oregon Health Plan does cover their care but there are not enough providers and there are wait times for treatments. She said that providers also don’t have much incentive to include more transgender patients or publicize that they serve this group.
Several people familiar with the coordinated care organizations’ work said they have long been committed to meeting the needs of transgender members. But they acknowledged gaps in care and two mentioned complications with electrolysis, a treatment that removes hair follicles.
A 2020 study based on interviews with 25 transgender women in Oregon suggested the state is “relatively trans-friendly.” Study participants reported ease in getting hormone therapy through the Oregon Health Plan, but encountered difficulties in navigating health services.
“What the letter of the law provides in terms of access to health care doesn’t always result in people receiving that care when it is being implemented,” said Jonathan Garcia, associate professor in Oregon State University’s College of Health, who is the study’s lead author. “It’s great that we have a legal framework that provides access to gender-affirming care. I also think we also have a long journey to implementing that access in a meaningful way.”
