Federal Authorities Probe Alleged Billing Fraud in Pediatric Gender Medicine

Federal authorities are intensifying investigations into potential medical billing fraud within the pediatric gender-affirming care sector, following allegations that providers may be miscoding treatments to secure insurance coverage. The scrutiny centers on the use of diagnostic codes for "doctor-caused" endocrine disorders in children receiving gender-affirming interventions.

Travis Morrell, MD MPH, recently highlighted the issue in a tweet, stating, "> Big news, long awaited, inevitable in a reality where words mean things. My comment: even if we accept these kids get doctor-caused “endocrine disorders” FROM their “gender medicine,” it’s still fraud to bill that code for the meds/procedures CAUSING the “disorder.”" This sentiment echoes growing concerns among critics and federal agencies.

Web search results indicate that a common practice under investigation involves the use of "Endocrine Disorder Not Otherwise Specified" (ICD-10 code E34.9) for billing purposes. This code is reportedly used instead of specific gender dysphoria codes (F64) to avoid "labeling" patients or to ensure insurance reimbursement, as some policies may not cover gender-affirming care directly. Studies have shown a high percentage of patients receiving gender-affirming therapy being coded with E34.9.

While gender-affirming hormone therapies can indeed induce endocrine disorders—such as iatrogenic hypogonadism or hyperandrogenism—the billing for these resulting conditions is being questioned when the initial interventions are part of a broader scheme involving potentially misleading diagnostic practices. Critics argue that deliberately inducing a condition and then billing for its treatment under a generic code constitutes fraud.

The Department of Justice (DOJ) has confirmed active investigations into healthcare fraud, false statements, and miscoding/misbilling related to gender-affirming care for minors. Chad Mizelle, Chief of Staff of the DOJ, stated that the department is seeking "to take down" the entire field of pediatric gender medicine, asserting that "the industry... has perpetuated one of the greatest frauds on the American public." Subpoenas have been issued to clinics and drug manufacturers. The Federal Trade Commission (FTC) is also examining deceptive practices in this area, emphasizing its role in protecting consumers from misleading health claims.

This federal crackdown comes amid a broader debate regarding the scientific evidence supporting pediatric gender-affirming care, the influence of advocacy groups like the World Professional Association for Transgender Health (WPATH), and the use of coercive narratives such as the "affirm or suicide" mantra. Critics argue that WPATH's guidelines, often cited by providers, lack robust scientific backing and have been influenced by political pressures, further complicating ethical and billing considerations.