Public Comment for Medicaid Policy Change Impacting Transgender Vermonters

Pride Center of Vermont 255 S Champlain St., Ste. 12 Burlington, VT 05401

June 16, 2022

Medicaid Policy Unit 280 State Drive, Center Building Waterbury, VT 05671-1000

To Whom It May Concern: Pride Center of Vermont became aware of your Global Commitment Register change to Hysterectomy Prior Authorization Requirements [GCR 21-068] and our organization has significant concerns about the exclusion of gender reaffirming surgery within this proposed change. In our work, we support LGBTQ+ (lesbian, gay, bisexual, transgender, queer, and questioning) Vermonters in overcoming the many barriers to services and care including, accessing safe and affirming healthcare and mental health providers, and addressing discrimination in service delivery. For too long our state’s systems have put an undue burden on our community to prove and validate what we already know to be true: that we know our bodies best and the care that we need.

This proposed change creates a discriminatory policy that treats a gender reaffirming surgery prescription as one that needs additional consideration, which we can only assume is due to bias and prejudice against transgender Vermonters. Your policy summary provides no justification nor reasoning for this exclusion other than to emphasize that hysterectomy surgical procedures related to gender reaffirming surgery will still require prior authorization, therefore calling out and targeting already marginalized people in our state. We implore you to reconsider the exclusion of gender reaffirming surgery in this policy change and to strive for health equity for all populations, especially for vulnerable Vermonters participating in the Medicaid program.

In Solidarity,

Mike Bensel, Executive Director

Kell Arbor, Director of Health & Wellness Program

Emily Russo, Transgender Program Coordinator