Dear Katherine Ceroalo, DOH Bureau of House Counsel, Regulatory Affairs Unit:
I support Trans, Gender Non Conforming, and Intersex New Yorkers in receiving adequate health care. I submit these comments to the New York State Department of Health because I believe the Proposed Rule to Amend Section 505.2(l) of Title 18 NYCRR (Transgender Related Care and Services) is an important step towards securing meaningful health care for all.
In particular, I write to support the fact that this regulation will remove the existing barrier to people under 21, which previously did not permit surgeries for some transgender people that may have resulted in sterilization. Thank you for removing this barrier.
This being said, the remaining exclusions in this proposed rule are still outdated and unnecessary. Procedures should be covered by Medicaid if they are medically necessary, and that decision should be made by a doctor and the patient. Many of the exclusions that exist in the rule are in fact, medically necessary. Such procedures often reduce the amount of harm and discrimination that transgender people experience, and moreover, may reduce the effects of gender dysphoria. Please take this in consideration.
I am also pleased that psychiatric nurse practitioners are now permitted to diagnose, and this is a huge step forward, however, general nurse practitioners should be able to diagnosis gender dysphoria as well. Such a change would permit many more transgender and gender non conforming people to access health care, as general nurse practitioners are more readily accessed and available.
Health care is vital to the stability and strength of any community. This affects everything from familial stability to education, employment, and stable housing. Meaningful access to healthcare for transgender, gender non-conforming, and intersex people is life-saving and I support this proposed amendment to the rule allowing people under the age of 21 to access appropriate health care.
Thank you for your consideration.
