A U.S. Department of Health and Human Services (HHS) report has identified $47.63 million in claim charges for puberty-blocker treatment involving 393 patients aged 9 to 17 between 2015 and 2025. The claims used endocrine-disorder diagnoses but, in the group examined, did not also include a diagnosis of gender dysphoria or central precocious puberty.
The findings come from Wolves in White Coats: How Doctors and Hospitals Pushed and Profited from the Fraud of “Gender Medicine,” an HHS-commissioned report examining insurance claims, medical coding and the financial side of gender-related treatment for minors. HHS says the coding patterns warrant further investigation. The agency has referred providers identified in its analysis to federal authorities, but the report does not establish fraud in every claim.
Commercial Insurance Accounted for Most Claims
Commercial insurance made up the largest share of the charges. Claims involving 298 patients totaled $37.51 million, while 55 Medicaid patients accounted for $7.79 million.
Another 36 patients were linked to an unidentified payer, representing about $2 million in charges. Medicare accounted for approximately $247,000 across two patients, while other government coverage represented roughly $97,000 across two patients.
The figures are based on claim charges, not necessarily the amounts ultimately paid by insurers or government programs. Claims can be adjusted, denied, or reimbursed at amounts below the original charge.
E34.9 Code Dominated the HHS Analysis
The report’s most prominent coding finding involves ICD-10 code E34.9, “Endocrine Disorder, Unspecified.” HHS says 239 patients in the analysis had puberty-blocker claims carrying that diagnosis, with approximately $42.59 million in charges.
Other E34-series diagnoses accounted for the remaining claims, including E34.8, E34.3 and several less frequently used endocrine codes.
HHS says the concern is not simply that an endocrine diagnosis appeared on a claim. Rather, the agency is examining why broad endocrine codes were used in cases where the claims did not also include a gender-dysphoria or central-precocious-puberty diagnosis. The underlying diagnosis can affect whether a treatment qualifies for insurance coverage.
The presence of E34.9 on a claim, however, does not by itself demonstrate inaccurate billing or fraud. That would require reviewing the clinical records, coding decisions and coverage requirements applicable to each claim.
HHS Raises Questions About E30.1 Claims
The report separately examines E30.1, the ICD-10 code for central precocious puberty.
HHS says it identified nearly $11 million in claims involving patients aged 13 to 17 that carried an E30.1 diagnosis. Puberty blockers are an established treatment for central precocious puberty, but HHS questioned the pattern of these claims because of the patients’ ages and the circumstances identified in its broader review.
This finding is part of the report’s wider coding analysis and should not be treated as an additional $11 million on top of the $47.63 million without considering the different groups examined.
Broader Review Found Nearly $120 Million in Charges
HHS also conducted a separate nationwide analysis covering gender-related services provided to minors since 2019. That review found nearly $120 million in billed charges, including more than 5,500 surgical procedures and approximately 8,500 courses of hormones or puberty blockers.
The broader $120 million estimate is separate from the 393-patient analysis and should not be added to the $47.63 million. Reuters reported that HHS relied in part on data from the medical advocacy organization Do No Harm for this wider estimate.
The agency also identified more than 225 hospitals and health systems with pediatric gender programs. Its claims analysis included high-volume providers such as Mount Sinai Hospital in New York and Boston Children’s Hospital.
Reuters reported that Mount Sinai did not respond to a request for comment before publication, while Boston Children’s said it was reviewing the report. The American Hospital Association declined to comment.
Providers Referred for Further Investigation
HHS has referred providers identified through its analysis to the HHS Office of Inspector General and the Department of Justice for possible investigation.
The referrals allow federal investigators to examine whether individual claims were supported by medical records, whether diagnoses were accurately reported and whether any billing practices violated federal requirements. A referral is not a finding of liability and does not mean that every claim or provider identified in the report was fraudulent.
The distinction is important because the HHS findings involve claims data and coding patterns, while a legal determination would require evidence about individual cases.
Federal Coverage Policy Is Also Changing
The report comes as the administration is changing federal funding rules for gender-related treatment involving minors.
A rule finalized earlier in August bars federal Medicaid and CHIP funding for puberty blockers, hormone therapy and surgeries used to treat gender dysphoria in minors. The policy is scheduled to take effect in October.
The administration says the change is intended to prevent federal funds from supporting treatments it considers insufficiently supported or harmful. Medical organizations opposing the policy argue that gender-affirming care can be clinically appropriate for some adolescents.
The coverage debate and the HHS billing review are related but distinct. One concerns which federal programs treatments should cover; the other concerns whether providers accurately documented and coded the care submitted for reimbursement.
What the HHS Findings Establish
For the 393-patient group, HHS identified $47.63 million in claim charges, with $42.59 million associated with E34.9. The agency says the coding patterns warrant further review and has sent relevant cases to federal investigators.
What has not yet been established is whether the claims reflected legitimate clinical documentation, inappropriate coding or conduct that could meet the legal definition of fraud. That determination will depend on the investigations that follow.
Bottom Line
The HHS report highlights a specific set of puberty-blocker claims involving 393 minors and questions the use of certain endocrine diagnoses in those cases. The $47.63 million figure represents billed charges, not confirmed fraudulent payments.
The central issue now is whether the diagnoses and billing information accurately reflected the care provided. The OIG and Justice Department investigations will determine whether individual claims involved violations of federal requirements.
