Analyses / Impact Analysis / 119 · HR 498 Impact Analysis

119-HR-498 Investigative Journalist Impact Analysis

119 · HR 498 Do No Harm in Medicaid Act

health_and_safety Health
Do No Harm in Medicaid ActThis bill prohibits federal Medicaid payment for specified gender transition procedures for individuals under the age of 18. The bill defines these procedures to mean those...
Bottom-line assessment
On balance, fiscal savings to the federal government are uncertain and likely modest in the near term given low baseline utilization among minors; however, access and administrative impacts for Medicaid‑reliant youth and providers are material. Evidence on benefits/harms is mixed across authorities (short‑term mental‑health improvements in some U.S. cohorts versus the Cass Review’s call for greater caution and research). Given these cross‑currents and the bill’s narrow financial scope but broader operational knock‑on effects, the overall assessment is neutral. [5]JAMA Pediatrics — Gender-Affirming Medications Among Transgender Adolescents in…[10]JAMA Network Open — Mental Health Outcomes in TNB Youths Receiving Gender-Affir…[14]NHS England — NHS England responds to the publication of the Cass Review (April…
Minors receiving GA hormones by age 17 (privately insured, 2018–2022)
0.1% (~100 per 100,000) [5]JAMA Pediatrics — Gender-Affirming Medications Among Transgender Adolescents in…
Adolescent GA surgeries (2019 rate, age 15–17)
2.1per 100,000 [3]JAMA Network Open — Prevalence of Gender-Affirming Surgical Procedures Among Mi…
Children covered by Medicaid/CHIP (Oct 2024)
49% of US children [6]American Academy of Pediatrics — AAP analysis: 49% of children insured by Medic…
Published
19 Dec 2025
Updated
19 Dec 2025
Tags
US Congress · Medicaid · Health Policy
Unvetted
01 · Section

Summary (Document 119-HR-498)

The bill prohibits federal Medicaid payments for specified gender‑transition procedures furnished to individuals under age 18 and bars federal administrative funds for any state program that furnishes such procedures to minors. It passed the House on December 18, 2025, and was referred to Senate Finance; no CBO score is posted as of December 19, 2025. [1]Congress.gov — Text - H.R.498 - 119th Congress (2025-2026): Do No Harm in Medic…[2]Congress.gov — H.R.498 - 119th Congress (2025-2026): Do No Harm in Medicaid Act…

02 · Section

Economic Effects

Who pays, who is exposed to risk, and where administrative friction enters the system.

  • Scope of the federal prohibition. H.R. 498 amends SSA §1903(i) to disallow FMAP for defined surgeries, implants, puberty‑suppressing drugs, and cross‑sex hormones for minors; it also denies federal administrative matching funds for a state program that furnishes such services to minors. Practically, states that continue coverage would need state‑only financing, ring‑fenced from federal admin dollars. [1]Congress.gov — Text - H.R.498 - 119th Congress (2025-2026): Do No Harm in Medic…
  • Magnitude of current use. Best available claims studies indicate very low utilization among minors: in 2019, rates of gender‑affirming surgery were ~2.1 per 100,000 for ages 15–17 (none <12), mostly chest procedures; a 2016–2019 series estimated ~1,130 adolescent chest surgeries nationally. A 2018–2022 claims study reports <0.1% of privately insured adolescents received puberty blockers or hormones. These baselines imply modest near‑term federal outlays at risk, but high sensitivity for affected families. [3]JAMA Network Open — Prevalence of Gender-Affirming Surgical Procedures Among Mi…[4]JAMA Pediatrics — Gender-Affirming Chest Reconstruction Among Transgender and G…[5]JAMA Pediatrics — Gender-Affirming Medications Among Transgender Adolescents in…
  • Which children are financially exposed. Roughly one‑half of U.S. children are insured by Medicaid/CHIP, so any categorical exclusion in Medicaid disproportionately affects low‑income youth compared with privately insured peers who may retain some coverage. [6]American Academy of Pediatrics — AAP analysis: 49% of children insured by Medic…
  • State budget choices and administrative burden. Because EPSDT requires coverage of medically necessary §1905(a) services for children, states that wish to cover these services despite the federal bar would have to use state‑only funds and create claims edits, program carve‑outs, and compliance controls to avoid federal cost allocation—raising admin costs and audit risk. [7]CMS/Medicaid.gov — Early and Periodic Screening, Diagnostic, and Treatment (EPS…
  • Market/provider effects. Clinics in states that still permit youth care could see payer mix shift away from Medicaid; others may exit minor care due to uncompensated demand, billing uncertainty, or legal risk under evolving state/federal rules—trends already observed as restrictions proliferated. [8]KFF — Policy Tracker: Youth Access to Gender Affirming Care and State Policy Re…
Minors receiving GA hormones by age 17 (privately insured, 2018–2022)
0.1% (~100 per 100,000) [5]JAMA Pediatrics — Gender-Affirming Medications Among Transgender Adolescents in…
Adolescent GA surgeries (2019 rate, age 15–17)
2.1per 100,000 [3]JAMA Network Open — Prevalence of Gender-Affirming Surgical Procedures Among Mi…
Children covered by Medicaid/CHIP (Oct 2024)
49% of US children [6]American Academy of Pediatrics — AAP analysis: 49% of children insured by Medic…
03 · Section

Social Effects

Distributional and equity implications for patients, families, and providers.

  • Affected population size. The Williams Institute’s 2025 update estimates ~724,000 youth ages 13–17 identify as transgender (~3.3%); the share directly seeking medical interventions is far smaller, but those who do and rely on Medicaid are most exposed to coverage loss. [9]UCLA Williams Institute — Williams Institute (2025): New estimate: 2.8 million…
  • Access and mental‑health outcomes. A prospective cohort found initiation of puberty blockers or GA hormones associated with lower odds of depression (aOR ~0.40) and suicidality (aOR ~0.27) over 12 months; however, evidence quality and generalizability are contested internationally (see Cass Review context below). Removing federal match may compound access barriers for low‑income youth. [10]JAMA Network Open — Mental Health Outcomes in TNB Youths Receiving Gender-Affir…
  • Geographic burdens. With state restrictions, median drive times to pediatric gender clinics have increased; loss of Medicaid coverage in permissive states would likely intensify cross‑state travel and waitlists, amplifying burdens on rural and low‑income families. [11]JAMA — State Restrictions and Geographic Access to Gender-Affirming Care for Tr…
  • Clinical standards dispute. Major U.S. specialty bodies (Endocrine Society) endorse a cautious, multidisciplinary pathway with no medical intervention prior to puberty and staged use thereafter; NHS England, following the 2024 Cass Review, has paused routine puberty blocker use for under‑18s and is shifting to a more research‑led model. Families and providers will face mixed signals amid diverging authorities. [12]Endocrine Society — Endocrine Society Clinical Practice Guideline (2017) – Gend…[13]Endocrine Society — Endocrine Society Statement in Support of Gender-Affirming…[14]NHS England — NHS England responds to the publication of the Cass Review (April…
  • Legal context. The Supreme Court’s June 18, 2025 decision in United States v. Skrmetti upheld a state ban under rational‑basis review, signaling federal courts’ deference to legislative limits on youth gender‑related care; this increases the likelihood that a federal Medicaid funding bar will withstand constitutional challenge while shifting disputes to statutory and administrative law. [15]Justia — United States v. Skrmetti, 605 U.S. ___ (2025) – Justia summary
04 · Section

Environmental Effects

Direct environmental pathways are limited; any effects are secondary to access changes.

  • Travel emissions. If families must travel farther for permitted services, vehicle miles and tailpipe CO2 rise marginally. EPA reports average new‑vehicle emissions near 319 g CO2/mile in MY2023; cumulative impacts remain de minimis at national scale but non‑zero for repeated long trips. [16]US EPA — EPA Automotive Trends – Highlights (CO2 g/mi, MY2023)
  • Pharmaceutical waste and supply chain. No direct change is mandated by the bill; shifts in demand from Medicaid to private cash‑pay channels would not materially alter national pharmaceutical waste streams. (No specific evidence of material environmental externalities identified.)
05 · Section

Temporal Analysis

Contrast near‑term operational effects with longer‑term system changes.

  1. 0–6 months after enactment: State Medicaid agencies implement edits and guidance; denials for minors appear in fee‑for‑service and MCO claims; clinics reassess Medicaid scheduling and intake for adolescents; some states weigh state‑only coverage carve‑outs to comply with EPSDT while avoiding federal cost allocation. [7]CMS/Medicaid.gov — Early and Periodic Screening, Diagnostic, and Treatment (EPS…
  2. 6–24 months: Access patterns consolidate—greater interstate travel to shield‑law/permissive states; provider concentration; potential increases in uncompensated care and charity programs. Litigation likely focuses on administrative law (e.g., conflicts with EPSDT determinations), not equal protection. [11]JAMA — State Restrictions and Geographic Access to Gender-Affirming Care for Tr…[15]Justia — United States v. Skrmetti, 605 U.S. ___ (2025) – Justia summary
  3. 24+ months: Policy path depends on Senate action, future HHS regulations, and state decisions on state‑only funding. Divergence between U.S. specialty guidelines and NHS England’s Cass‑informed service model may persist, continuing uncertainty over standard‑of‑care signals to payers and courts. [12]Endocrine Society — Endocrine Society Clinical Practice Guideline (2017) – Gend…[14]NHS England — NHS England responds to the publication of the Cass Review (April…
06 · Section

Unintended Consequences

Risks and secondary effects documented or reasonably foreseeable from analogous policy shifts.

  • Program chilling effects. Because the bill also withholds federal administrative funds for any state program that furnishes defined services to minors, states may adopt broader‑than‑required restrictions to simplify compliance and minimize audit exposure. [1]Congress.gov — Text - H.R.498 - 119th Congress (2025-2026): Do No Harm in Medic…
  • Equity impacts. Low‑income and rural adolescents—overrepresented in Medicaid—bear disproportionate travel and continuity‑of‑care burdens relative to privately insured peers, even though overall utilization numbers are small. [6]American Academy of Pediatrics — AAP analysis: 49% of children insured by Medic…[11]JAMA — State Restrictions and Geographic Access to Gender-Affirming Care for Tr…
  • Clinical standard fragmentation. Divergent guidance (Endocrine Society vs. Cass‑informed NHS model) complicates determinations of medical necessity and may spur payer disputes and inconsistent coverage decisions. [13]Endocrine Society — Endocrine Society Statement in Support of Gender-Affirming…[14]NHS England — NHS England responds to the publication of the Cass Review (April…
07 · Section

Assessment (Analytical Stance)

On balance, fiscal savings to the federal government are uncertain and likely modest in the near term given low baseline utilization among minors; however, access and administrative impacts for Medicaid‑reliant youth and providers are material. Evidence on benefits/harms is mixed across authorities (short‑term mental‑health improvements in some U.S. cohorts versus the Cass Review’s call for greater caution and research). Given these cross‑currents and the bill’s narrow financial scope but broader operational knock‑on effects, the overall assessment is neutral. [5]JAMA Pediatrics — Gender-Affirming Medications Among Transgender Adolescents in…[10]JAMA Network Open — Mental Health Outcomes in TNB Youths Receiving Gender-Affir…[14]NHS England — NHS England responds to the publication of the Cass Review (April…

08 · Section

Sourcing

Key materials used in this assessment.

  • Bill text and status: Congress.gov H.R. 498 (119th). [1]Congress.gov — Text - H.R.498 - 119th Congress (2025-2026): Do No Harm in Medic…[2]Congress.gov — H.R.498 - 119th Congress (2025-2026): Do No Harm in Medicaid Act…
  • Population and coverage context: Williams Institute (2025 update) and AAP analysis of Medicaid/CHIP coverage. [9]UCLA Williams Institute — Williams Institute (2025): New estimate: 2.8 million…[6]American Academy of Pediatrics — AAP analysis: 49% of children insured by Medic…
  • Utilization studies: JAMA Network Open (surgery rates, 2019); JAMA Pediatrics (adolescent chest reconstruction 2016–2019); JAMA Pediatrics (hormone/puberty‑blocker prevalence, 2018–2022). [3]JAMA Network Open — Prevalence of Gender-Affirming Surgical Procedures Among Mi…[4]JAMA Pediatrics — Gender-Affirming Chest Reconstruction Among Transgender and G…[5]JAMA Pediatrics — Gender-Affirming Medications Among Transgender Adolescents in…
  • Clinical standards and international posture: Endocrine Society guideline and statement; NHS England response to Cass Review. [12]Endocrine Society — Endocrine Society Clinical Practice Guideline (2017) – Gend…[13]Endocrine Society — Endocrine Society Statement in Support of Gender-Affirming…[14]NHS England — NHS England responds to the publication of the Cass Review (April…
  • Access and secondary impacts: JAMA analysis of geographic access; KFF policy tracker on state restrictions. [11]JAMA — State Restrictions and Geographic Access to Gender-Affirming Care for Tr…[8]KFF — Policy Tracker: Youth Access to Gender Affirming Care and State Policy Re…
  • Environmental proxy: EPA Automotive Trends (CO2 g/mi). [16]US EPA — EPA Automotive Trends – Highlights (CO2 g/mi, MY2023)
  • EPSDT framework: Medicaid.gov EPSDT page. [7]CMS/Medicaid.gov — Early and Periodic Screening, Diagnostic, and Treatment (EPS…
  • Legal backdrop: United States v. Skrmetti (2025) summary. [15]Justia — United States v. Skrmetti, 605 U.S. ___ (2025) – Justia summary
Sources cited
  1. [1] Text - H.R.498 - 119th Congress (2025-2026): Do No Harm in Medicaid Act Congress.gov
  2. [2] H.R.498 - 119th Congress (2025-2026): Do No Harm in Medicaid Act (Overview & Actions) Congress.gov
  3. [3] Prevalence of Gender-Affirming Surgical Procedures Among Minors and Adults in the US (2019) JAMA Network Open
  4. [4] Gender-Affirming Chest Reconstruction Among Transgender and Gender-Diverse Adolescents in the US From 2016 to 2019 JAMA Pediatrics
  5. [5] Gender-Affirming Medications Among Transgender Adolescents in the US, 2018–2022 (Research Letter) JAMA Pediatrics
  6. [6] AAP analysis: 49% of children insured by Medicaid or CHIP (Oct 2024 data) American Academy of Pediatrics
  7. [7] Early and Periodic Screening, Diagnostic, and Treatment (EPSDT) | Medicaid.gov CMS/Medicaid.gov
  8. [8] Policy Tracker: Youth Access to Gender Affirming Care and State Policy Restrictions (updated Nov. 24, 2025) KFF
  9. [9] Williams Institute (2025): New estimate: 2.8 million people aged 13+ identify as transgender (incl. ~724k youth) UCLA Williams Institute
  10. [10] Mental Health Outcomes in TNB Youths Receiving Gender-Affirming Care (Prospective Cohort) JAMA Network Open
  11. [11] State Restrictions and Geographic Access to Gender-Affirming Care for Transgender Youth JAMA
  12. [12] Endocrine Society Clinical Practice Guideline (2017) – Gender Dysphoria/Incongruence Endocrine Society
  13. [13] Endocrine Society Statement in Support of Gender-Affirming Care (May 8, 2024) Endocrine Society
  14. [14] NHS England responds to the publication of the Cass Review (April 10, 2024) NHS England
  15. [15] United States v. Skrmetti, 605 U.S. ___ (2025) – Justia summary Justia
  16. [16] EPA Automotive Trends – Highlights (CO2 g/mi, MY2023) US EPA
  17. [17] Web search · turn 7 #3
  18. [18] Web search · turn 11 #3

Discussion