Attorney General Kwame Raoul, along with a coalition of 20 attorneys general, has submitted comment letters opposing two proposed federal rules that would restrict access to transgender healthcare for youth. The rules, put forward by the United States Department of Health and Human Services (HHS) and the Centers for Medicare and Medicaid Services (CMS), could result in hospitals and medical providers being unable to provide care by threatening the loss of Medicare and Medicaid funding.
“These proposed rules are the Trump administration’s latest attempt to undermine the essential rights of youth living with gender dysphoria across the nation, including in states like Illinois that has enacted robust laws to protect their right to receive clinically prescribed healthcare,” Raoul said. “These rules greatly exceed the administration’s authority because no federal agency has the power to directly regulate healthcare—a traditional and congressionally recognized power reserved for the states. I will continue to push back on these unlawful policy changes and efforts by the federal government to upset the balance of power between states and the federal government.”
The CMS proposals from December 2025 would bar hospitals from providing medically necessary transgender healthcare to youth by withholding funds from those that continue such care. Additionally, they would prevent state Medicaid and Children’s Health Insurance Program (CHIP) plans from using federal money for this type of care.
According to Raoul and his coalition, these proposed regulations would take away states’ authority as administrators of Medicaid programs. They argue that hospitals in Illinois could lose critical funding not only for transgender healthcare but also for all services if they offer care to transgender youth. The coalition asserts that CMS lacks legal authority to override states’ ability to regulate medical practices intended for residents’ safety.
The attorneys general claim in their letters that these new rules violate state rights, contradict various statutes—including the Social Security Act and Affordable Care Act—and go against nondiscrimination laws. They also argue HHS is discriminating against transgender youth without adequate scientific backing or required regulatory analysis.
The coalition pointed out flaws in a key report cited by CMS, stating it was methodologically unsound due to its anonymous publication without peer review and its origins as a directive from the president aimed at ending transgender health care. The letters also note unaddressed financial impacts on affected families, patients, and providers.
Raoul was joined by attorneys general from Arizona, California, Colorado, Connecticut, Delaware, District of Columbia, Maine, Maryland, Massachusetts, Michigan, Minnesota, Nevada, New Jersey, New York, Oregon, Rhode Island, Vermont, Washington and Wisconsin.
As part of its broader mission described on its official website, the Illinois Attorney General’s office acts as the state’s chief legal officer supporting residents through protective services while advocating for vulnerable groups such as workers and seniors. The office emphasizes consumer protection initiatives alongside efforts related to community safety and environmental issues across Illinois.
