Sexual and gender minority adults experience inequity in accessing health insurance and healthcare. Ceasing efforts to collect data on sexual orientation and gender identity effectively renders it impossible to identify where there may be disparities in healthcare, health coverage, and more. This has impacts on both research into health equity and future actions to address inequity. It may also further embolden those who deny healthcare services to LGBTQ+ populations.
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Department of Health and Human Services
A written policy statement issued by a government agency or executive official that provides guidance, clarification, or direction on implementing laws or policies. Memos do not have the force of law but can influence policy interpretation and enforcement.
Who It Impacts: Federal agencies, policymakers, and sometimes regulated industries. Memos can shape how agencies enforce laws, impacting businesses, healthcare providers, and other stakeholders.
Who Is Not Impacted: Memos do not create binding legal requirements for the general public, though they can influence enforcement priorities that indirectly affect individuals and organizations.
Date Enacted
June 5, 2025
Last Updated
December 10, 2025
Policy Type
Healthcare Coverage
Research and Data
LGBTQI+ Health
Summary
This memo rescinds the Center for Medicaid and CHIP Services (CMCS) Informational Bulletin, Guidance on Adding Sexual Orientation and Gender Identity Questions to State Medicaid and CHIP Applications for Health Coverage. The rescission is due to a decision to stop collecting information on sexual orientation and gender identity as part of Transformed Medicaid Statistical Information System (T-MSIS) data submissions. Affected agencies and individuals include those involved with Medicaid and the Children’s Health Insurance Program (CHIP).
Impact Analysis
Legal Challenges
N/A
Take Institutional Action
Encourage your state to collect this data. The current guidance recommends making this collection optional, not mandatory. States can add these questions to their forms to make data available for identifying and addressing disparities. Health centers should review the original guidance, and use it to gather data not collected at the federal level.
Associated or Derivative Policies
N/A
Policy Prior to 2025
Guidance on Adding Sexual Orientation and Gender Identity Questions to State Medicaid and CHIP Applications for Health Coverage
Additional Resources
N/A
