Medicaid Regulations and Guidance (Archived)
To learn about state Medicaid policies on transgender-related health care, see the Movement Advancement Project’s interactive map.
If you know of a resource that is missing or have first-hand knowledge of the coverage situation in a particular state, please contact the Movement Advancement Project.
The Trans Health Project historically compiled information on all aspects of transgender-related coverage under Medicaid. In addition to our own research, we built on the work of NCTE, the Movement Advancement Project, and the Williams Institute. Below is an archive of past Medicaid policies compiled by the Trans Health Project. Please see the time stamp at the bottom of each page to see when the information was last updated.
Alabama
Alabama Medicaid has no explicit policy regarding transgender-related health care.
Last updated on Jun 10, 2021.
Alaska
Alaska Medicaid policy covers transgender-related health care.
Regulations
-
Text:
"surgical procedures to alter a recipient's body to conform to recipient's gender identity" (effective July 25, 2021)
Decisions:
-
Court Decision: Being v. Crum, No. 3:19-cv-00060-HRH (D. Alaska filed Dec. 30, 2019)
Summary:
Three transgender plaintiffs challenged Alaska's Medicaid exclusion under Section 1557 of the Patient Protection and Affordable Care Act, 42 U.S.C. § 18116; the comparability and availability requirements of the federal Medicaid Act, 42 U.S.C. §§ 1396a(a)(10)(A)-(B); and the Equal Protection Clause of the U.S. Constitution.
Pursuant to a settlement agreement reached in January 2021, Alaska repealed the exclusion and added affirmative coverage effective July 25, 2021.
Last updated on Jun 29, 2021.
Arizona
Arizona Medicaid policy excludes transgender-related health care.
Regulations
-
Text:
The following services are excluded from AHCCCS coverage: a. . . . gender reassignment surgeries
Last updated on Jun 10, 2021.
Arkansas
Arkansas Medicaid has no explicit policy regarding transgender-related health care.
Notes:
If you have been denied transgender-related care under an Arkansas Medicaid plan, please contact us.
Last updated on Jun 9, 2020.
California
California Medicaid policy covers transgender-related health care.
Statutes:
-
Insurance Gender Nondiscrimination Act - Health and Safety Code Section § 1365.5
Text:
INGA applies to Medi-Cal managed care plans.
Decisions:
-
Court Decision: J. D. v. Lackner, 80 Cal. App. 3d 90 (Ct. App. 1978)
Summary:
Requiring coverage for transgender surgery under California’s Medi-Cal program because trans surgeries do not fall under the cosmetic exclusion. "We do not believe, by the wildest stretch of the imagination, that such surgery can reasonably and logically be characterized as cosmetic."
-
Court Decision: G.B. v. Lackner, 80 Cal. App. 3d 64 (Cal. App. 1978)
Summary:
Requiring coverage for transgender surgery under California’s Medi-Cal program because trans surgeries do not fall under the cosmetic exclusion.
-
Court Decision: Jane Doe v. Diana M. Bonta, No. 00CS00954 (Cal. Super. Ct. Sacramento Cty. Jan. 29, 2001)
Summary:
California Department of Health Services ordered to approve Jane Doe’s request for surgery, rescind department policy automatically denying coverage for trans-related procedures under Medi-Cal, and review all future requests on a case-by-case basis.
Guidance and Announcements:
- Guidance: DHCS All Plan Letter 16-013 (2016)
Handbooks and Provider Manuals:
- Provider Manual: Medi-Cal Provider Manual, Transgender Services (May 2022)
Notes:
An Advocate’s Guide to Medi-Cal Services
Last updated on Mar 6, 2023.
Colorado
Colorado Medicaid policy covers transgender-related health care.
Regulations
-
Text:
Health First Colorado clients with a clinical diagnosis of gender dysphoria are eligible for benefits under § 8.735 for services that are medically necessary.
Guidance and Announcements:
Handbooks and Provider Manuals:
- Provider Manual: Health First Colorado Transgender Services Benefit
Notes:
While Colorado Medicaid regulations require an individual to be 18 to undergo surgery, there is no lawful basis to restrict medically necessary care on the basis of age.
Last updated on Jun 10, 2020.
Connecticut
Connecticut Medicaid policy covers transgender-related health care.
Handbooks and Provider Manuals:
- Provider Manual: Provider Policies and Procedures
Notes:
2022 changes to the provider manual include:
- surgery is only available to people age 18 and older
- surgery requires evaluations from 2 mental health professions, the most recent within six months of the request
- additional changes to coverage requirements for facial gender reassignment (facial feminization) surgery, among other procedures
Last updated on Jun 23, 2022.
Delaware
Delaware Medicaid policy covers transgender-related health care.
Handbooks and Provider Manuals:
- Provider Manual: Practitioner Provider Specific Policy Manual
Last updated on Aug 2, 2022.
District of Columbia
District of Columbia Medicaid policy covers transgender-related health care.
Guidance and Announcements:
- Guidance: Non-Discrimination Publication (2014)
- Guidance: Policy OD-001-17 (2016)
Last updated on Jun 10, 2021.
Florida
Florida Medicaid has no explicit policy regarding transgender-related health care.
Clinical Policies:
Last updated on Mar 6, 2023.
Georgia
Georgia Medicaid policy covers transgender-related health care.
Decisions:
-
Court Decision: Rush v. Parham, 625 F.2d 1150, 1157 n.12 (5th Cir. 1980)
Summary:
Observing that a categorical denial of healthcare simply “because it was transsexual surgery” would violate Medicaid laws, but allowing it to be denied as "experimental" in 1980.
Clinical Policies:
- Amerigroup - Gender Reassignment Surgery
- CareSource - Gender Dysphoria
- Peach State Health Plan - Gender Affirming Surgery
- WellCare - Gender Reassignment Surgery
Notes:
Managed care organizations operating under Georgia's Medicaid program have clinical policy guidelines for covering transgender-related care.
Last updated on Feb 11, 2025.
Hawaii
Hawaii Medicaid policy covers transgender-related health care.
Statutes:
Last updated on Jun 10, 2021.
Idaho
Idaho Medicaid has no explicit policy regarding transgender-related health care.
Last updated on Jun 10, 2021.
Illinois
Illinois Medicaid policy covers transgender-related health care.
Guidance and Announcements:
- Announcement: IDHFS announcement (2019)
Last updated on Jun 10, 2021.
Indiana
Indiana Medicaid has no explicit policy regarding transgender-related health care.
Last updated on Apr 29, 2021.
Iowa
Iowa Medicaid policy excludes transgender-related health care.
Statutes:
-
HF 766, 2019-2020 Reg. Sess. (Iowa 2019).
Text:
Adds subsection three to the state public accommodations nondiscrimination statute (Iowa Code § 216.7 (2019)), which prohibits discrimination on the basis of gender identity in public accommodations or services. Subsection three specifies that "[t]his section shall not require any state or local government unit or tax-supported district to provide for sex reassignment surgery or any other cosmetic, reconstructive, or plastic surgery procedure related to transsexualism, hermaphroditism, gender identity disorder, or body dysmorphic disorder."
Decisions:
-
Administrative Decision: Vasquez v. Iowa Dep't of Human Services
Summary:
The ACLU of Iowa and national ACLU LGBT and HIV Project filed a lawsuit to block implementation of an Iowa law that specifically allows denial of coverage under Medicaid of essential, gender-affirming surgery to transgender Iowans.
-
Summary:
The Iowa district court struck down Iowa’s categorical Medicaid ban as discrimination under the Iowa Civil Rights Act and the Iowa Equal Protection Clause, as violative of privacy rights, and as unreasonable, arbitrary and capricious. The Iowa Supreme Court held that the exclusion is discrimination under the Iowa Civil Rights Act.
-
Court Decision: Smith v. Rasmussen, 249 F.3d 755 (8th Cir. 2001)
Summary:
The Eighth Circuit Court of Appeals declined to overturn a Medicaid surgery ban where hormones were covered but not surgery.
-
Court Decision: Pinneke v. Preisser, 623 F.2d 546 (8th Cir. 1980)
Summary:
The Eighth Circuit Court of Appeals struck down Iowa’s Medicaid transgender exclusion, which “reflect[ed] inadequate solicitude for the applicant’s diagnosed condition, the treatment prescribed by the applicant’s physicians, and the accumulated knowledge of the medical community.”
Last updated on Apr 29, 2021.
Kansas
Kansas Medicaid has no explicit policy regarding transgender-related health care.
Last updated on Feb 4, 2020.
Kentucky
Kentucky Medicaid policy excludes transgender-related health care.
Notes:
Managed care plans in Kentucky have exclusions for "sex change services."
If you have been denied transgender-related care under a Kentucky Medicaid plan, please contact us.
Last updated on Feb 22, 2021.
Louisiana
Louisiana Medicaid policy covers transgender-related health care.
Clinical Policies:
- Aetna - Gender Reassignment Surgery
- AmeriHealth Caritas - Gender Dysphoria
- Healthy Blue - Endometrial Ablation
- Healthy Blue - Gender Reassignment Surgery
- Louisiana Healthcare Connections (Centene Corporation)
- UnitedHealthcare - Gender Dysphoria Treatment (Community Plan)
Notes:
While there is no official guidance from the Louisiana Department of Health, the managed care organizations operating under Louisiana's Medicaid program have clinical policy guidelines for covering transgender-related care.
If you have been denied transgender-related care under a Louisiana Medicaid plan, please contact us.
Last updated on Jun 6, 2020.
Maine
Maine Medicaid policy covers transgender-related health care.
Regulations
-
Text:
This regulation eliminates gender affirmation procedures and care from exclusion under MaineCare. "Services related to gender transition that otherwise fall within a member’s scope of covered MaineCare benefits (e.g., physician services, inpatient and outpatient hospital services, prescribed drugs) will be compensable under the MaineCare program when medically necessary."
Handbooks and Provider Manuals:
- Handbook: MaineCare Benefits Manual
Last updated on Jun 18, 2020.
Maryland
Maryland Medicaid policy covers transgender-related health care.
Guidance and Announcements:
- Guidance: PT 37-16 (2016)
Handbooks and Provider Manuals:
- Provider Manual: Professional Services Provider Manual
Notes:
The coverage extension excludes some hair removal and facial surgery as outlined on page 3 of the guidance document.
Last updated on Jun 18, 2020.
Massachusetts
Massachusetts Medicaid policy covers transgender-related health care.
Clinical Policies:
- Boston Medical Center HealthNet Plan - Gender Affirmation Surgeries
- Fallon Health - Gender Affirming Services
- Tufts Health Plan - Transgender Surgical Procedures
Guidance and Announcements:
Notes:
If you have been denied transgender-related health care under MassHealth, Health Law Advocates is an organization that assists transgender people to challenge those denials.
Last on Jun 14, 2020.
Michigan
Michigan Medicaid policy covers transgender-related health care.
Handbooks and Provider Manuals:
Last updated on Jun 14, 2020.
Minnesota
Minnesota Medicaid policy covers transgender-related health care.
Decisions:
-
Court Decision: OutFront Minnesota v. Johnson Piper, No. 62-CV-15-7501 (Minn. Dist. Ct. Nov. 14, 2016)
Summary:
A Minnesota district court found that a categorical exclusion for sex reassignment surgery violates the Minnesota Constitution's guarantees of equal protection and the right of an individual to have authority over their own body.
-
Court Decision: Doe v. Minnesota Department of Public Welfare, 257 N.W. 2d 816 (Minn. 1977)
Summary:
The Minnesota Supreme Court found that (1) total exclusion of transsexual surgery from Medical Assistance coverage is void under federal regulations governing state Medicaid programs; (2) a standard of medical necessity that requires conclusive proof that a procedure will eliminate disability and render the applicant self-supporting is impermissible; and (3) the decision to deny Medical Assistance funding in the absence of evidence to contradict the applicant's showing of medical necessity is arbitrary and unreasonable.
Handbooks and Provider Manuals:
- Provider Manual: Minnesota Provider Manual
Last updated on Jun 10, 2021.
Mississippi
Mississippi Medicaid has no explicit policy regarding transgender-related health care.
Last updated on Jun 10, 2021.
Missouri
Missouri Medicaid policy excludes transgender-related health care.
Handbooks and Provider Manuals:
- Provider Manual: State of Missouri Physician Manual (2019)
Notes:
"Although it is not possible to list every situation or procedure that is noncovered through the Physician Program, the following list has been compiled: ...
Surgical procedures for gender change such as:
- Hysterectomy
- Mammoplasty
- Mastectomy
- Orchiectomy
- Penectomy
- Penile construction
- Release of vaginal adhesions
- Revision of labia
- Vaginal dilation
- Vaginal reconstruction
- Vaginoplasty;"
State of Missouri Physician Manual (2019), p. 226-227.
Last updated on Jun 10, 2021.
Montana
Montana Medicaid policy covers transgender-related health care.
Guidance and Announcements:
Notes:
While the original Medicaid guidance page is not on the website, Montana state Medicaid representatives have reported no policy change since original 2017 guidance.
Last updated on Jun 10, 2021.
Nebraska
Nebraska Medicaid policy excludes transgender-related health care.
Guidance and Announcements:
- Guidance:
- Guidance: 471 NAC 10-004 (pg. 207; since 1990)
Last updated on Jun 10, 2021.
Nevada
Nevada Medicaid policy covers transgender-related health care.
Guidance and Announcements:
- Announcement: Web Announcement 1532 (2018)
Last updated Jun 10, 2021.
New Hampshire
New Hampshire Medicaid policy covers transgender-related health care.
Statutes:
Handbooks and Provider Manuals:
Last updated on Jun 10, 2021.
New Jersey
New Jersey Medicaid policy covers transgender-related health care.
Statutes:
Decisions:
-
Administrative Decision: M.K. v. Div. Med. Assistance & Health Servs., 92 NJAR2d (DMA) 38, 1992 WL 280789 at *9 (N.J. Admin. 1992)
Summary:
Ordering coverage of genital reassignment surgery under NJ Medicaid and rejecting arguments that it was experimental and/or cosmetic.
Last updated on Jun 10, 2021.
New Mexico
New Mexico Medicaid has no explicit policy regarding transgender-related health care.
Last updated on Jun 9, 2020.
New York
New York Medicaid policy covers transgender-related health care.
Regulations
Decisions:
-
Summary:
A federal district court found that a categorical ban on medically necessary treatments for a specific diagnosis, gender dysphoria, violates the federal Medicaid Act’s Availability Provision.
Guidance and Announcements:
Handbooks and Provider Manuals:
- Provider Manual: NYS Medicaid Physician Procedure Codes - Surgery
Last updated on Jun 7, 2021.
North Carolina
North Carolina Medicaid has no explicit policy regarding transgender-related health care.
Last updated on Jun 9, 2020.
North Dakota
North Dakota Medicaid has no explicit policy regarding transgender-related health care.
Last updated on Jun 9, 2020.
Ohio
Ohio Medicaid has no explicit policy regarding transgender-related health care.
Regulations
-
OH OAC 5160-2-03 (2017; since 2015)
Text:
5160-2-03 Conditions and limitations.
(A) Conditions and limitations applicable to both inpatient and outpatient hospital services.
(2) Inpatient or outpatient services related to the provision of the services described in this rule are not covered:
(e) Gender transformation.
Clinical Policies:
Notes:
Even though there is an explicit exclusion on the books, both the Washington Post and Bloomberg Law report that Ohio is not enforcing the exclusion.
Managed care organizations operating under Ohio's Medicaid program have clinical policy guidelines for covering transgender-related care.
Last updated on Apr 29, 2021.
Oklahoma
Oklahoma Medicaid has no explicit policy regarding transgender-related health care.
Last updated on Jun 9, 2020.
Oregon
Oregon Medicaid policy covers transgender-related health care.
Regulations
-
Exception Criteria for Facial Gender Confirmation Surgery (FGCS)
Text:
Facial gender confirmation surgery is covered only by exception in the OHP benefit. OHP has established exception processes; however, this OAR is needed to add clarity to the general exception processes for considering facial gender confirmation surgery services. The criteria in the OAR will enable the CCOs and the state to make exception determinations in a timely and efficient manner. While each case will still be considered in its own right, the OAR will lend to greater consistency in the determinations being made across the state. OHA is adopting this coverage by a specific administrative rule, rather than through usual HERC procedures in order to enhance compliance with civil rights laws.
Rule Text:
(1) The following definitions apply to this rule:
(a) “Community Life Activities” means activities such as but not limited to attending school or participating in employment;
(b) “Facial Gender Confirmation Surgery” means a constellation of surgical procedures intended to produce facial features that will be perceived by others as congruent with an individual’s gender identity. The goal of facial gender confirmation surgery is to reduce gender non-congruence that causes persistent gender dysphoria and severe life interruptions such as the impairment of an individual’s ability to participate in community life. Facial gender confirmation surgery may include but is not limited to frontal bone reshaping, mandible bone reshaping, cheek augmentation, rhinoplasty, tracheal shaving, and electrolysis or laser hair reduction procedures, depending on the severity of non-congruence of individual facial features;
(c) “Severe Mental Health Comorbid Condition,” for the purposes of this rule, means a condition such as but not limited to PTSD or anxiety including agoraphobia, severe depression, or suicidal ideation, due to experiencing or fear of experiencing physical violence based on marked facial gender non-congruence.
(2) Facial Gender Confirmation Surgery for treatment of gender dysphoria is not paired with gender dysphoria above the funded line on the Prioritized List of Health Services as referenced in OAR 410-141-0520. A member who meets the following criteria may be considered for coverage of medically necessary and appropriate facial gender confirmation procedures:
(a) Having a severe mental health comorbid condition that prevents the member from participating in community life; and
(b) Member receives medically necessary and appropriate non-surgical treatments for mental health comorbidity as recommended by the treatment team, and non-surgical treatments are determined to be insufficient to enable participation in community life; and
(c) Member experienced a gender identity non-congruent hormonal puberty; and
(d) Purpose of the surgery is to achieve a minimum level of facial gender congruence in order to be publicly identified as gender congruent and not solely to improve appearance; and
(e) Facial gender confirmation surgery is necessary to achieve the benefits of the funded treatments for gender dysphoria: Mental health care, hormone therapy, and sex reassignment surgery also known as gender confirmation surgery; and
(f) Member meets all the applicable requirements in Guideline Note 127, Gender Dysphoria of the Prioritized List in subsections (a, b, and d) for cross-sex hormone therapy and subsection (f) for sex reassignment surgery, also known as gender confirmation surgery, as referenced in OAR 410-141-0520;
(g) All other conditions of OAR 410-141-0480(11) are met;
(h) The surgery is medically necessary and appropriate as defined in OAR 410 120 0000.
Guidance and Announcements:
- Guidance: Gender Dysphoria criteria extracted from the February 1, 2021 Prioritized List
- Guidance: Prioritized List of Health Services (see Guideline Note 127, Gender Dysphoria)
- Guidance: Prioritized List: Guideline for Gender Dysphoria - Frequently Asked Questions
Handbooks and Provider Manuals:
- Handbook: OHP Handbook
Last updated on Apr 29, 2021.
Pennsylvania
Pennsylvania Medicaid has no explicit policy regarding transgender-related health care.
Clinical Policies:
- Gateway Health - Gender Transition Services
- Highmark Blue Cross Blue Shield (Pennsylvania) - Gender Affirmation Surgery
- UPMC Health Plan - Gender Affirmation Surgery
Guidance and Announcements:
Last updated on Jun 14, 2021.
Puerto Rico
Puerto Rico Medicaid policy excludes transgender-related health care.
Notes:
Hormones are covered, but surgery is excluded.
Drugs and hormones that are part of the ASES drug formulary are available for gender dysphoria treatments. See Michael Lavers, Puerto Rico Medicaid program now covers transition-related health care, Washington Blade (Oct. 15, 2020).
The Government Health Insurance Plan (MI Salud) excludes "Procedures for sex changes, including hospitalizations and complications."
Last updated on Jul 5, 2022.
Rhode Island
Rhode Island Medicaid policy covers transgender-related health care.
Guidance and Announcements:
Last updated on Apr 29, 2021.
South Carolina
South Carolina Medicaid policy excludes transgender-related health care.
Clinical Policies:
Handbooks and Provider Manuals:
- Provider Manual: Healthy Connections - Physician Services Provider Manual
Last updated on Dec 20, 2022.
South Dakota
South Dakota Medicaid has no explicit policy regarding transgender-related health care.
Last updated on Jun 9, 2020.
Tennessee
Tennessee Medicaid policy excludes transgender-related health care.
Regulations
-
Tenn. Comp. R. & Regs. 1200-13-13-.10
Text:
Regulations exclude the following care:
- Tenn. Comp. R. & Regs. 1200-13-13-.10(60) "Psychogenic sexual dysfunction or transformation services"
- Tenn. Comp. R. & Regs. 1200-13-13-.10(72) "Sex change or transformation surgery"
- Tenn. Comp. R. & Regs. 1200-13-13-.10(86) "Transsexual surgery"
Notes:
Providers report that hormones have been covered.
Last updated on Jul 30, 2020.
Texas
Texas Medicaid policy excludes transgender-related health care.
Handbooks and Provider Manuals:
- Provider Manual: Texas Medicaid Provider Manual (since at least 2019)
Notes:
Excludes "Sex change operations." Providers report hormone therapy has been covered.
Last updated Feb 4, 2021.
Utah
Utah Medicaid policy covers transgender-related health care.
Notes:
Providers in Utah report their patients can access hormones and surgery under Utah Medicaid. This is also supported by the findings in Michael Zaliznyak, et al., Which U.S. States' Medicaid Programs Provide Coverage for Genital Gender Affirming Surgery for Transgender Patients? A State-By-State Review, and a Study Detailing the Patient Experience to Confirm Coverage of Services, 203 Journal of Urology e144 (May 14, 2020).
Last updated on Jun 9, 2020.
Vermont
Vermont Medicaid policy covers transgender-related health care.
Regulations
-
Health Care Administrative Rule 4.238
Text:
Vermont Medicaid beneficiaries who are diagnosed with and receiving treatment for gender dysphoria, who satisfy all conditions set forth in this rule, and for whom the service(s) for which prior authorization is sought is both medically necessary and developmentally appropriate are eligible for coverage of the services governed by this rule.
Last updated on Apr 29, 2021.
Virginia
Virginia Medicaid policy covers transgender-related health care.
Handbooks and Provider Manuals:
- Provider Manual: DMAS Gender Dysphoria Supplement
Notes:
Virginia's policy continues to exclude body contouring, voice surgery, and fertility preservation. Also, some facial gender reassignment surgeries are covered, but others are excluded.
Last updated on May 27, 2022.
Washington
Washington Medicaid policy covers transgender-related health care.
Regulations
Guidance and Announcements:
- Guidance: Transgender Health Services Program
Handbooks and Provider Manuals:
- Provider Manual: Washington Apple Health (Medicaid) Physician-Related Services/Health Care Professional Services Billing Guide
Last updated on Jun 9, 2020.
West Virginia
West Virginia Medicaid policy excludes transgender-related health care.
Handbooks and Provider Manuals:
- Provider Manual: West Virginia Medicaid Provider Manual, Ch 100 (listing "transsexual surgery" as a non-covered service)
Notes:
Hormone therapy is not excluded.
Litigation challenging the exclusion has been filed by Lambda Legal: Fain v. Crouch.
Last updated on Nov 13, 2020.
Wisconsin
Wisconsin Medicaid policy covers transgender-related health care.
Decisions:
-
Court Decision: Flack v. Wisconsin Dep’t of Health Servs., 395 F. Supp. 3d 1001 (W.D. Wis. 2019)
Summary:
Struck down Wisconsin Medicaid exclusion under § 1557 of the Affordable Care Act, Availability and Comparability Provisions of the Medicaid Act, and Equal Protection.
The case settled for $2.2 million, including compensatory damages to the four individual Plaintiffs and attorney's fees and costs.
Guidance and Announcements:
Notes:
When the exclusion was removed, a Millman report, Wisconsin Department of Health Services Capitation Rate Development January 1, 2020 through December 31, 2020 SSI Medicaid Managed Care Programs, concluded, "DHS added coverage for transgender services in response to a permanent injunction signed on October 31, 2019. We did not apply an explicit adjustment to the capitation rates for this additional coverage because we determined the impact of this change is expected to be immaterial."
Last updated on Jun 5, 2020.
Wyoming
Wyoming Medicaid has no explicit policy regarding transgender-related health care.
Handbooks and Provider Manuals:
Notes:
Even though there is still an exclusion in the Medicaid Handbook, the Washington Post reported in July 22, 2019, that this exclusion is no longer in effect.
Last updated on Apr 29, 2021.
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