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PictureHHS Study Rebuts Utah Report
Utah Transgender Medical Report Got It Wrong
August 2025


In 2023, the Utah Legislature passed S.B. 16 Transgender Medical Treatments and Procedures Amendments, which was signed into law on January 28, 2023.  The law put into place a ban on transgender medical treatments for minors. It also required the Utah Department of Health and Human Services (DHHS) to conduct a systematic medical evidence review of the use of hormonal agents in the medical treatment of transgender minors under the age of 18 with gender dysphoria.  The Systematic Medical Evidence Review of Hormonal Transgender Treatment Report can be viewed here.


The conclusion of the Utah DHHS Report: “Policies that prevent access to hormone therapy for minors cannot be justified based on scientific findings or concerns about potential regret in the future, the report states.” The Utah DHHS also took no position on whether the legislature should lift the moratorium on minors receiving transgender treatments.

Featured in the rebuttals to the Utah Report are excerpts from the Treatment for Pediatric Gender Dysphoria Review of Evidence and Best Practices done by the U. S. Department of Health and Human Services which was prompted by an executive order signed by President Donald Trump at the end of January, 2025, as well as links to other studies and articles.
 
The U.S. HHS Review, released on May 1, 2025, is an evidence-based medicine approach and reveals serious concerns about medical interventions - such as puberty blockers, cross-sex hormones, and surgeries - that attempt to transition children and adolescents away from their sex.  It was prepared by experts in endocrinology, the methodology of evidence-based medicine, medical ethics, psychiatry, health policy and social science, and general medicine.

The conclusions in the U.S. HHS Review highlight a growing body of evidence pointing to significant risks—including irreversible harms such as infertility—while finding very weak evidence of benefit. That weakness has been a consistent finding of systematic reviews of evidence around the world.
 
Alex Byrne, a professor of philosophy at MIT, one of the doctors who participated in the U.S. HHS Review, said, “We agree with the health authorities in Sweden, who reached the same conclusion in 2022…After surveying all the evidence, and applying widely accepted principles of medical ethics, we found that medical transition for minors is not empirically or ethically justified …The review is a sober examination of what by any standards are drastic medical interventions for physically healthy minors.”
 
Utah Report’s Assertions Rebutted
 

Utah Report on Policies that Prevent Access: The ban on gender medical treatments for minors in Utah is not justified: “Policies that prevent access to hormone therapy for minors cannot be justified based on scientific findings or concerns about potential regret in the future, the report states.”

Rebuttal: Policies that allow access to hormone therapy for minors cannot be justified based on scientific findings and concerns about future regret.  “Suicide rates among those ages 12 to 23 rose (p. 13, Chart 2) in states with provisions that allow minors to access health care without parental consent, after cross-sex treatments became available.”  See the Heritage Foundation’s findings, “Puberty Blockers, Cross-Sex Hormones, and Youth Suicide.”

Utah Report on Use of Off-Label Treatments: From p. 6 of Utah‘s DHHS PDF Executive Summary of the Report to the Utah Legislature Health and Human Services Interim Committee: “…administering [hormonal treatments for minors] off-label has become the standard of care.”  

“The evidence base for gender-affirming care is robust, with over 230 primary studies, exceeding the evidence required for FDA approval of many high-risk pediatric treatments.  Off-label use of medications, a common practice in pediatrics, was deemed appropriate and not a valid reason for restrictions.”

Rebuttal: Hormonal treatments for gender transition have not been approved by the U.S. Food and Drug Administration to treat gender dysphoria. Even the Utah Report admits that the Hormonal Transgender Treatment Board (HTTB), on the PDF Executive Summary of the Report to the Utah Legislature Health and Human Services Interim Committee, (pp. 11-12) “should…be empowered to conduct an ongoing review of the evidence related to hormonal transgender treatments and to amend their recommendations on a regular basis” because of the fact that said hormonal treatments have not been approved by the FDA for treatment of gender dysphoria (GD). “This could, for example, mean providing recommendations to rescind or revise regulations that permit the use of hormonal transgender treatments that are later found to be unhelpful for gender dysphoria.”

Utah Report on Adverse Effects from Trans Treatments: “…the evidence also supports that the treatments are safe in terms of changes to bone density, cardiovascular risk factors, metabolic changes, and cancer.  The report also found no significant long-term safety concerns.

Rebuttal: From The American College of Pediatricians: Up to one third of gender dysphoric patients treated with puberty blockers have a lower bone density than 97.7% of their age matched peers.

From the U.S. HHS review, 7.3.2 (p. 110) Bone Mineral Density and Skeletal Development: “Puberty is recognized as providing a critical window for the accrual of peak bone mass. Sex steroid hormones play an essential role in the mineralization of the skeleton. Failure to reach peak bone density may lead to increased risk of osteopenia, osteoporosis, and fractures later in life, including debilitating fractures of the spine and hip.

Effects of Cross Sex Hormones (CSH) Specific to Females: 7.4.1 (p. 115-117) Physical effects of cross-sex hormones: Under the influence of high doses of testosterone, females may develop facial and body hair, cystic acne, male pattern scalp hair distribution, male-pattern baldness, clitoral growth, changes in musculature, thickening of vocal cords leading to voice deepening, and alterations in fat deposition; Testosterone can cause reproductive organ atrophy, including thinning and atrophy of vaginal epithelium, persistent pelvic pain and discomfort, and pelvic floor dysfunction. …sexual maturation that makes possible reproduction—is not and cannot be obtained.”

“In females, testosterone can cause elevated blood pressure, polycythemia, and atherogenic changes in the lipid profile.” “Several studies and reviews have found increased risk of Cardio Vascular (CV) events like heart attacks and strokes in females taking testosterone.” (p. 118)

Effects of CSH Specific to Males:  7.4.1 (p. 115-116) Physical effects of cross-sex hormones: “…males receiving high doses of estrogen may experience significant breast tissue growth (gynecomastia), reduced muscle mass, change in skin texture, and may develop a more typically female pattern of fat distribution… testicular atrophy results, leading to impaired fertility or infertility that may be irreversible (even if estrogen were to be discontinued).”  (p. 112-113)

(p. 119) “In males taking estrogen, studies have shown increased risk of CV events like venous thromboembolism and stroke.” “Another study found that men who identify as transgender face a 30% higher risk of stroke than men who do not.”

7.4.8, (p.119) Other risks associated with cross-sex hormones “In both sexes, CSH use may be associated with early mortality.”

From the U.S. HHS review, 7.4.7 (p. 118) Cardiovascular and Metabolic Risks: “Among the most significant long-term risks associated with cross-sex hormones (CSH) is an increase in cardiovascular risk factors. A 2018 review found that patients taking CSH had an elevated risk of heart attack and cardio vascular (CV) mortality compared to controls.”

“Among females, even modest elevations in hematocrit levels have been independently associated with heightened risks of CV disease, coronary events, and CV-related mortality.”

(p. 119) “In males taking estrogen, studies have shown increased risk of CV events like venous thromboembolism and stroke.”

 “With the use of testosterone on the female reproductive tract, there is evidence for the risk of cancer.” (p.117) 

In females taking testosterone, there is “concern about possible increased risk of breast and ovarian cancer. In males, some studies suggest that estrogen may increase risk of developing multiple sclerosis and thyroid cancer, and that it may lead to a decrease in brain volume.” (p. 119)

Even the Utah Report itself “acknowledged certain risks associated with gender-affirming care, including an increase in some types of benign brain tumors.”

From the U.S. HHS review, 7.7 Mortality risk (p. 124)  “In the U.S., private insurance data from 2011 to 2019 indicated that transgender persons were nearly twice as likely to die as age- and sex-matched controls. A Dutch cohort study that included five decades of data found that compared to their natal sex peers, transgender people had an elevated standardized mortality ratio (higher risk of death). A 2023 cohort study from the U.K. found that compared to their natal sex peers, transgender people had higher risk of mortality (34% higher for females, 60% higher for males). Finally, a Swedish study that included three decades of data found that the mortality risk for transgender persons was 2.8 times that of age and natal sex matched population controls.”

 “These studies further support a cautionary stance toward PMT (Pediatric Medical Transition)….”

Providing these hormonal treatments at all may be unnecessary, considering most gender-confused children become gender-conforming adults. “A new study has found that almost all children who experience gender confusion grow out of it as they age into adulthood.”

“We found that gender non-contentedness is most common around the age of 11 and that the prevalence decreases with age.”

 Utah Report on Effects of Gender-Affirming Care Treatments on Mental Health:  Utah's Department of Health and Human Services and experts from the state's leading health organizations concluded from a study of thousands of transgender people that gender-affirming care generated "positive mental health and psychosocial functioning outcomes." 

“Youth receiving such care before age 18 had lower suicide risks compared to those starting as adults.” 
 
"When left untreated, individuals with gender dysphoria may experience psychological and social harms,” the report notes.

Rebuttal:  From the U.S. HHS Review, 7.6.1 Adverse Psychiatric Effects, (p. 121). “There is a dearth of research on psychotherapeutic approaches to managing gender dysphoria in children and adolescents. This is due in part to the mischaracterization of such approaches as “conversion therapy.” A more robust evidence base supports psychotherapeutic approaches to managing common comorbid mental health conditions. Psychotherapy is a noninvasive alternative to endocrine and surgical interventions for the treatment of pediatric gender dysphoria. Systematic reviews of evidence have found no evidence of adverse effects of psychotherapy in this context”.

“Reported psychological harms included anxiety, depression, mood swings, suicidal ideation and behavior, aggression, dissociation, and self-harm. More extreme symptoms, such as antisocial behavior and homicidal ideation, were also documented.”

From the U.S. HHS Review, 7.3.3 Neurocognitive and psychosocial development, (p. 111-112) “The human brain undergoes substantial reorganization during adolescence, including synaptic pruning and myelination, processes that are influenced by sex steroid hormones. Research suggests that sex steroid hormones impact brain regions associated with executive function, emotion regulation, and social cognition. The precise neurocognitive effects of puberty suppression remain understudied, and researchers in this field have recognized the limitations of the evidence in this area.”

The Cass Review has raised concern over the potential harm and unknown effects of pubertal suppression on the developing brain, noting that “[t]here is increasing evidence that the changes in brain maturation described above are driven by a combination of chronological age and sex hormones released through puberty.”

From the U.S. HHS Review, 7.6.1 Adverse psychiatric effects, (p.121- 122) “The FDA-mandated labeling for testosterone cautions about abuse potential, noting: “Research on anabolic steroid misuse has demonstrated associations with severe psychiatric problems, including mood instability, psychosis, and dependence. The most frequently observed symptoms include irritability, aggression, euphoria, inflated self-perception, impulsivity, and risk-taking behaviors” and self-harm. Symptoms are applicable to adolescents.

The head of a transgender clinic published a study finding transgender surgeries do not improve mental health and actually make patients feel lonelier. 

Utah Report on Surgeries:  The study claims that gender-affirming surgeries, such as operations to transform the chest or genitals, are rarely performed on minors. The study also emphasized that “surgeries — especially bottom surgeries — are not recommended for minors.” 

Rebuttal: “From January 2019 to December 2023, 13,994 minor patients received gender-transition treatments, with 5,747 undergoing sex-change surgeries and 8,579 getting hormones and puberty blockers, according to Do No Harm’s database.”  The numbers are likely an underestimate because the data “does not include patients covered by Kaiser Health Plans, the Veterans Association, charity payments, or self-pay, as Do No Harm says these forms of payment are not publicly reported or accessible.”

It is not necessary to refute the Utah Report’s claim since it does not recommend trans surgeries for minors.  

Utah Report on Suicide: "Patients that were seen at the gender clinic before the age of 18 had a lower risk of suicide compared to those referred as an adult," the report states. "When left untreated, individuals with gender dysphoria may experience psychological and social harms."

“…the Drug Regimen Review Center’s review for Utah officials indicated transgender individuals who receive care at a gender clinic before the age of 18 are less likely to commit suicide — a risk transgender people of all demographics are disproportionately prone to.”
 
“Experts highlighted the positive impact of such (hormonal) treatments in mitigating the risk of suicide among transgender youth.” 
 
Rebuttal: “Using a superior research design, the new analysis finds that increasing minors’ access to cross-sex interventions is associated with a significant increase in the adolescent suicide rate.”

The Heritage Foundation’s study concluded that “easier access by minors (their study was with ages 12-23) to cross-sex medical interventions without parental consent is associated with higher risk of suicide.” 

 “…some studies actually suggest that suicidal thoughts increase among those taking these drugs.”

A Danish study drew on four decades of health data and concluded transgender people have a higher risk of suicide than the general population.

The Heritage study asks about suicide rates longer term.  It includes a reference to "(t)he most thorough follow-up of sex-reassigned people—extending over 30 years and conducted in Sweden...,  (t)en to 15 years after surgical reassignment, the suicide rate of those who had undergone sex-reassignment surgery rose to 20 times that of comparable peers."  [Heritage Foundation]

Utah Report on Regret and Detransition:  The review also found that “regret” associated with treatment is extremely rare. In fact, among the 32 studies examining regret, researchers found it was “virtually nonexistent” — and when present, it was “only a very minor proportion” of treatment discontinuation.

Rebuttal:   From the U.S. HHS Review, (p. 122-124), 7.6.2 Detransition and regret - “This serious issue has been minimized with the claim that detransition and regret rates are vanishingly low. In fact, the detransition rate is unknown. The ubiquitous claim that the detransition and regret rates are vanishingly low is unsupported by the evidence. A U.K. population-based study not focused on minors found that about one-fifth of patients discontinued hormonal interventions within five years, with more than half of them reporting experiences of detransition and/or regret.”

“With respect to clinical research studies of children and adolescents, one study reported a 7.1% regret rate, two found low rates of cross-sex hormone (CSH) discontinuation or reidentification with birth sex (<5%), and one found a higher rate of CSH discontinuation (25%).”

Conclusion:  With the Utah study rebutted on so many points, one has to wonder whether transgender ideology motivated its authors and whether the Transgender-Industrial Complex had a hand in producing the report. 


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