Utah Health Department Issues Flawed Report on ‘Gender-Affirming Care’ for Minors as State Weighs Ban

A Utah Department of Health and Human Services report published in defense of pediatric gender interventions cites unreliable, low-quality research, but was nevertheless presented as comprehensive evidence for a push within the state legislature to codify access to the procedures.

Utah HHS worked with the University of Utah's Drug Regimen Review Center to produce a report pushing back on the state’s existing moratorium on hormone treatments and gender-transition surgeries for minors. Presented to the state legislature in May, the report emphasizes the positive effects of so-called gender-affirming care in minors while excluding the many well-documented downsides associated with the procedures. The report comes as some lawmakers in the state are pushing to make the ban permanent in the 2026 legislative session.

“This Utah Report is unreliable, unscientific, and fails to meet the standards of a systematic review. The Report's inaccuracies and bias diminish its credibility and allow left-wing activists to weaponize it for their political machinations,” said Michelle Havrilla, CRNP and director of programs of gender ideology for the medical watchdog group Do No Harm, which recently published its own report pushing back on Utah HHS’s findings.

“Utah legislators must not rely on a report that clearly undermines the safety and well-being of minors,” she said.

When asked about the report and Do No Harm’s subsequent report, the University of Utah declined to comment. Utah HHS also failed to respond to a request for comment.

Democratic Utah State Senator Luz Escamilla and State Representative Angela Romero encouraged their colleagues to read the full report back in May when Utah DHHS released its research. Both members are the minority leaders of their respective caucuses.

National Review reached out to both members to ask whether they still maintain their support of the report, but neither responded to requests for comment.

The report’s authors claimed to have examined the medical histories of 28,000 transgender minors and found “virtually no regret associated with receiving the treatments.” Yet, the report did not take concerns regarding fertility into account, and although the report acknowledges these interventions “may lead to irreversible physical changes,” the authors conclude that “Overall, there were positive mental health and psychosocial functioning outcomes.”

“It is our expert opinion that policies to prevent access to and use of (gender-affirming hormone therapy) for treatment of (gender dysphoria) in pediatric patients cannot be justified based on the quantity or quality of medical science findings or concerns about potential regret in the future,” the report states.

In contrast, both England’s National Health Service and the U.S. Department of Health and Human Services found in their own reviews that prescribing hormones to minors leads to a significant risk of decreased bone density, stunted brain development, and fertility issues.

The Cass Review, which was completed in 2024, is a systematic review published by Dr. Hilary Cass that led to England’s National Health Service banning the provision of puberty blockers to minors.

The U.S. Department of Health and Human Services came to a similar conclusion with its own report, titled “Treatment for Pediatric Gender Dysphoria,” published in 2025. HHS said the quality of research that supports gender interventions is of low quality and ignores concerns around fertility and bone density.

“These interventions carry risk of significant harms including infertility/sterility, sexual dysfunction, impaired bone density accrual, adverse cognitive impacts, cardiovascular disease and metabolic disorders, psychiatric disorders, surgical complications, and regret, and there has been inadequate research into the frequency and severity of these harms,” the HHS report reads. “Meanwhile, systematic reviews of the evidence have revealed deep uncertainty about the purported benefits of these interventions.”

In addition to ignoring the downsides included in the Cass Review and the HHS report, the Utah report also fails to meet the basic standards of a systematic review, according to Do No Harm.

The report “does not assess the reliability of studies and whether the research can provide guidance for weighing the risks and benefits of medical intervention for children with gender dysphoria,” Do No Harm researchers found.

Besides researchers failing to scrutinize the reliability of the studies included, the report did not register the study with a systematic review platform, which would have allowed outside researchers to scrutinize the underlying research.

The report only included research from 2023 to 2024 and six of the seven reviews cited in the report received a “critically low” reliability rating by a leading review appraisal tool.

A “critically low” rating for systematic reviews means that the study not only presents many fatal flaws, but the findings should not be used to make any make important policy or clinic decisions.

“When experts highlight the lack of evidence for pediatric gender transition, they are not pointing to the number of studies but to their poor methodological quality and the resulting uncertainty in the findings,” the Do No Harm report explained. “The problem lies not in the amount of ‘evidence,’ but in its substantial weakness and very low quality.”

Thus, the report asserts that puberty blockers and cross-sex hormones are safe and effective for minors, without addressing the fact that it references observational studies which focus on narrative summaries rather than research rooted in quantitative synthesis.

Utah Republicans, such as Representative Mike Kennedy and State Representative Katy Hall, told Deseret News that they agree with the Do No Harm report and its findings, characterizing the HHS report as biased and unfit to educate lawmakers.

“Common sense is common sense,” Schultz said. “I don't need a report, one way or the other, to tell me that. I just firmly believe that minors should not be transitioning.”