There are moments when disagreement over public policy is legitimate. There are moments when medical standards deserve serious debate. There are moments when government should investigate fraud, misconduct, or improper insurance billing.

And then there are moments when government takes legitimate concepts like “fraud,” “patient safety,” and “protecting children,” wraps them around a predetermined political conclusion, and calls the result science.

The Human Rights Alliance believes the August 13 report released by the U.S. Department of Health and Human Services, grotesquely titled Wolves in White Coats: How Doctors and Hospitals Pushed and Profited from the Fraud of “Gender Medicine,” belongs squarely in that latter category.
HHS says its report examines insurance coding practices surrounding gender-affirming care for minors. It points specifically to approximately $50 million in claims for puberty blockers billed under the ICD-10 code E34.9, “Endocrine Disorder, Unspecified,” and nearly $11 million in claims involving patients ages 13 through 17 billed under a precocious-puberty diagnosis. HHS says those findings warrant additional review and has referred hospitals and clinics for possible investigation.

Read those words again: warrant additional review. Possible violations. Investigation.

Those are not findings of fraud.
Yet HHS did not title its report Questions Concerning Insurance Coding Practices That Merit Further Investigation.

It called it Wolves in White Coats.
That tells us quite a bit about what this document is designed to accomplish.

If There Is Fraud, Investigate Fraud
Let us begin somewhere that should not be controversial.
If a physician, hospital, clinic, pharmacy, or insurance company knowingly submits fraudulent claims, investigate it. If the evidence demonstrates wrongdoing, hold the responsible party accountable.

HRA has no interest in defending insurance fraud. Fraudulent billing steals resources from patients, taxpayers, and health programs.

But allegations of improper coding are not proof that an entire field of medicine is fraudulent.
That distinction matters enormously.

Indeed, HHS’s own announcement says the report identified billing patterns that “warrant additional review,” refers to “potentially improper billing practices,” and sends providers to investigators for possible violations of federal law.

You cannot simultaneously tell the American public that an investigation must determine whether fraud occurred and announce in your headline that you have already “exposed” the fraud.
Well, apparently you can.

But that isn’t neutral investigation. That is a verdict looking for evidence.
Language Is Doing Much of the Work Here
Notice the vocabulary.

HHS repeatedly calls gender-affirming health care “sex-rejecting procedures.” Its report title places “gender medicine” in quotation marks and calls physicians “wolves.” It describes patients as “captive.”

Those are not clinical terms.
They are political messaging.
And they serve a purpose: to make transgender health care sound inherently sinister before the reader reaches the evidence.

Gender-affirming care is not one procedure. It can encompass psychological, behavioral, social, pharmaceutical, and medical care, depending upon the individual patient, their age, their circumstances, clinical judgment, applicable law, and informed decision-making.
Even the American Medical Association’s current policy recognizes medical and surgical treatments for gender dysphoria and gender incongruence, when determined through shared decision-making between physician and patient, as medically necessary under generally accepted standards of practice. The AMA also opposes governmental policies that criminalize or impede evidence-based gender-affirming care.
One may debate particular interventions, ages, evidence standards, consent requirements, or clinical protocols. Medicine does that constantly.
That is called medicine.

Turning those debates into accusations that physicians caring for transgender patients constitute an industry of predatory “wolves” is something else entirely.

The Great Coding Sleight of Hand
The central rhetorical trick deserves particular scrutiny.
HHS identifies claims submitted under diagnostic codes and argues that some of those claims may indicate improper billing. That is a legitimate subject for auditing.
But a suspicious code is not, standing alone, a criminal conviction.

Medical billing is complicated. Coding practices can be inaccurate, inconsistent, overly broad, outdated, disputed, or in some cases intentionally fraudulent. Determining which explanation applies requires examination of individual records, medical necessity, payer requirements, documentation, intent, and applicable billing rules.
That is precisely why investigations exist. Yet the administration moves almost immediately from questions about coding to condemnation of the underlying care.

That is the sleight of hand.
The public is encouraged to hear:
Some claims may have been improperly coded.
and conclude:
Therefore gender-affirming health care itself is fraudulent.

Those propositions are not remotely the same.
If a cardiologist improperly codes a cardiac procedure, cardiology does not become fraudulent.
If an orthopedic practice submits an improper claim for spinal surgery, we do not issue a federal report called Wolves with Scalpels declaring orthopedics a conspiracy.

We investigate the billing.
Transgender medicine deserves exactly the same standard.
This Is Bigger Than Insurance Codes
This report also cannot honestly be separated from the administration’s broader campaign against transgender health care.

Just two days before releasing Wolves in White Coats, HHS announced implementation of a rule ending federal Medicaid and CHIP funding for what the administration again calls “sex-rejecting procedures” for children and youth.
That context matters.

The government is not approaching this subject as a disinterested auditor that happened upon questionable claims.

It has already announced its policy objective.
Now comes a report whose title declares physicians predatory, whose terminology adopts the administration’s ideological framing, and whose findings are being used to justify further investigations of providers.

That should concern every American, whether transgender or cisgender.
Because once government learns that it can politically target one category of medicine by portraying physicians as criminals and patients as victims before investigations are completed, there is nothing inherently limiting that machinery to transgender health care.

Today it is gender-affirming medicine.
Tomorrow it can be reproductive medicine.
HIV prevention.
Contraception.
Intersex health care.
Fertility treatment.
Vaccination.
End-of-life medicine.

The principle at stake is much larger than any one medical specialty: Should politicians determine appropriate individualized medical treatment, or should patients, families, and qualified clinicians make those decisions within legitimate standards of medical care?

And Yes, This Hurts Children
The cruelest part of this campaign may be that it is repeatedly conducted in the name of “protecting children.”

Transgender and Gender Expansive young people are actual children.
They attend our schools. They play in our parks. They sing in choirs, complain about homework, roll their eyes at their parents, leave dishes approximately six inches away from the dishwasher, and do all of the other things children and teenagers have done since approximately the dawn of time.

They are not an ideology.
They are human beings.
And they hear what their government says about them.
They hear adults describe their health care as mutilation.
They hear politicians describe their identities as sickness.
They watch physicians who care for people like them portrayed as predators.
Then we somehow expect them to believe us when we tell them that they are valued.

We cannot terrorize young people rhetorically and call it protection.
New Mexico Must Hold the Line

Fortunately, New Mexico has already articulated a profoundly different principle.
Our Reproductive and Gender-Affirming Health Care Freedom Act defines gender-affirming health care broadly to include psychological, behavioral, pharmaceutical, surgical, and medical care supporting a person’s gender identity. It prohibits public bodies from directly or indirectly denying, restricting, or interfering with a person’s ability to access or provide such care within the medical standard of care.

Those final words matter.
Within the medical standard of care.
Not whatever anyone wants.
Not medicine without oversight.
Not treatment without ethical obligations.

Medical care.
New Mexico has chosen regulation over demonization, medical judgment over political theater, and bodily autonomy over ideological government intrusion.
We should be extraordinarily reluctant to surrender those principles now.

What We Do Next
Outrage without action eventually becomes exhaustion. So our response cannot end with another angry social media post.

First, challenge the language. Do not casually repeat “sex-rejecting procedures” as though it were an accepted medical term. Call it what it is: political terminology created to frame the debate before the debate begins.

Second, insist on the distinction between allegations and findings. When politicians say HHS “proved fraud,” correct them. HHS itself says particular billing patterns warrant review and referred providers for investigation of possible violations. Investigation is not conviction.
Third, defend New Mexico’s protections. Contact legislators, the Governor, the Attorney General, health regulators, school leaders, and local officials. Tell them clearly that New Mexico must continue protecting lawful gender-affirming health care and the professionals who provide it.
Fourth, support providers. Doctors, nurses, therapists, pharmacists, social workers, clinics, and hospitals caring for transgender and Gender Expansive people are increasingly being asked to practice medicine with politicians peering over their shoulders. They need legal protection, institutional support, and public solidarity.

Fifth, protect families. Parents making difficult health-care decisions with their children and
medical professionals should not have to wonder whether the federal government will someday portray their physician as a criminal for providing care that was lawful and professionally appropriate.
Sixth, demand evidence rather than propaganda. Ask elected officials and journalists the simplest question imaginable: What exactly has been proven? Separate confirmed billing violations from statistical anomalies, suspected miscoding, disputed medical necessity, and political assertions about gender-affirming care itself.

Finally, show up. Write. Call. Testify. Vote. Support organizations defending LGBTQIA2S people. Correct misinformation when you hear it. Stand beside transgender and Gender Expansive New Mexicans when their humanity becomes somebody else’s political talking point.
Because silence is precisely what campaigns

like this depend upon.
The Human Rights Alliance will not be silent.
We will condemn fraud when fraud is proven.
We will support appropriate oversight of medicine.
We will support rigorous science, informed consent, ethical medical practice, patient safety, and accountability.

And we will also name political propaganda when we see it.
Transgender people are not fraudulent.
Gender Expansive children are not an ideology.
Parents who love them are not accomplices.
And medical professionals who care for them are not “wolves.”
Here in New Mexico, our answer must remain unmistakable:
Medicine belongs in the examination room, not on the campaign stage.
Transgender young people deserve care, dignity, safety, and truth.
And when their government chooses fear over truth, we choose them.

The Human Rights Alliance of Santa Fe

Standing for dignity, equality, bodily autonomy, and the human rights of LGBTQIA2S New Mexicans.