A report commissioned by the U.S. Department of Health and Human Services (HHS) and published earlier this month accused UChicago Medicine (UCMed) and more than 200 other healthcare providers of improperly billing insurance companies for medical care the report says was provided to transgender minors.

UCMed, the report alleges, “used misleading or potentially fraudulent diagnostic and procedural codes in securing insurance coverage,” billing insurance companies at least once for puberty blockers and describing the medication as necessary to treat precocious (early) puberty in patients between 13 and 17 years old.

The report does not provide specific evidence to support its allegations, including that the patients in question were transgender. Instead, it cites the ages of patients, all between 13 and 17 years old, to cast doubt on the documented reason for prescribing puberty blockers. Pediatricians generally agree that puberty is no longer precocious after age eight in girls and nine in boys and typically recommend ending treatment between ages 10 and 12.

Diagnosing patients with precocious puberty was intended to increase the likelihood of insurance coverage for puberty blockers—also a common early treatment for gender dysphoria—the report argues. 

According to the report, which says it examined an unspecified database of medical billing and insurance claims, approximately 300 patients across the providers were improperly diagnosed with precocious puberty and prescribed puberty blockers between 2015 and 2025, at an estimated cost of $11.1 million billed to private and government insurance.

The report does not indicate when or how frequently the alleged activity at UCMed took place—inclusion in the report indicates only that at least one bill was submitted—nor does it distinguish between mistaken and intentional uses of inaccurate diagnostic codes or identify whether insurance companies ultimately paid for treatment in question.

Vice President JD Vance has since referred the report to the Department of Justice (DOJ) for investigation. In a statement, the DOJ told the Maroon that it “has received the referral from Vice President Vance and takes allegations of health care fraud seriously,” and that it will “review the referral carefully and will not hesitate to pursue additional cases where the evidence supports it.”

At the time of publication, UCMed had not responded to multiple requests for comment from the Maroon that included questions about its practices related to insurance billing.

Doctors use standardized sets of codes to maintain statistics, classify treatments and diagnoses, and document of the “medical necessity” of treatments for insurance purposes. The International Classification of Diseases, 10th Revision (ICD-10) system, in use since 2015, is a set of codes developed and maintained by federal health agencies to classify diagnoses and some services. Another set of codes, the Current Procedural Terminology (CPT) system, is maintained by the American Medical Association and used to classify treatments. When the ICD and CPT codes align—for example, with a diagnosis of precocious puberty and a prescription of puberty blockers—insurance companies are more likely to cover the cost of treatment.

According to government data, inaccurate uses of these codes account for about 10 percent of improper Medicare and Medicaid payments. In 2024, “incorrect coding”—when a provider bills for an ICD or CPT code that does not reflect the services provided or the appropriate diagnosis or treatment—accounted for 49.1 percent of all coding-related improper payments, which includes both intentional and unintentional errors.

It is unclear how common this phenomenon is in the private insurance market.

HHS Press Secretary Emily Hilliard told the Maroon in a statement that the report “draws on peer-reviewed scientific literature, federal guidance, hospital records, claims data, whistleblower testimony, and firsthand patient and parent accounts to examine pediatric gender medicine and its institutional, financial, and policy drivers.”

When asked how the report reached its conclusions or whether the claims had been independently verified, HHS said the “analysis identified claims carrying a precocious puberty diagnosis for patients ages 13–17.”

“As stated in the report, these findings are directional signals that require verification against underlying medical records. An organization’s inclusion in the appendix means it billed at least one claim meeting the report’s criteria,” HHS said.

Federal agencies under the second Trump administration have broadly sought to cast doubt on the existence of transgender people and restricted access to gender-affirming care for both adults and minors.

The Center for Medicare and Medicaid Services, in conjunction with the release of the HHS report, issued a final rule August 11 prohibiting the use of federal Medicaid funds for coverage of pediatric gender-affirming care. Trump has signed numerous executive orders directed at what he calls “gender ideology” and called for the restoration of “biological truth to the federal government.”

UChicago Medicine’s Trans CARE clinic, established in 2021, provided a wide array of gender-affirming care—including hormone therapy, surgery referrals, and mental health care—to adults and adolescents until 2025, when the program stopped providing care to minors amid threats from the Trump administration to withhold Medicare and Medicaid funding.

UCMed did not respond to requests for comment about its diagnostic criteria for providing hormone treatments or how many patients the Trans CARE clinic treated before it stopped providing care to minors.