When a medical organization publishes one set of guidelines for doctors and families, then says something noticeably different to federal regulators, people who trust that organization deserve to know about it. That’s the core of what’s now playing out in Washington – and it touches something many health-conscious parents and patients have felt for years: the sense that the institutions meant to guide our medical decisions don’t always speak with one voice.
A medical group called Do No Harm filed a formal letter on April 20, 2026, asking the Federal Trade Commission to open an investigation into the American Psychological Association (APA). The charge is pointed: that the APA has been holding two contradictory positions on gender-affirming medical care for minors, one for public consumption and one for regulators. Whether or not you have a strong view on gender medicine itself, the question of whether a powerful medical body is saying different things to different audiences is worth paying close attention to.
The APA is one of the most influential psychological organizations in the United States. Its policy positions shape how tens of thousands of psychologists, counselors, and clinicians advise patients and families every single day. When families with children experiencing gender dysphoria (significant distress caused by a mismatch between a person’s gender identity and their biological sex) sit across from a mental health provider, that provider’s guidance is often shaped, directly or indirectly, by what the APA says is best practice. So what happens when that guidance turns out to be inconsistent?
The Two Positions at the Heart of the Complaint
According to Do No Harm, the APA holds a 2024 policy that promotes gender-affirming care for minors, but also sent a 2025 letter to the FTC that takes a noticeably more cautious tone.
The gap between those two documents is what triggered the complaint. The 2024 policy statement endorses an affirmation-only approach to treating gender dysphoria, going so far as to equate “non-affirmation” with “violence” and “discrimination.” That is a strong, unqualified position. It implies that any provider who pauses before affirming a child’s stated gender identity is causing harm.
Then, in 2025, the APA submitted a comment to the FTC that read very differently. According to Do No Harm’s letter, the APA’s 2025 submission admits there is a “lack of long-term scientific evidence” supporting child sex change procedures, encourages a more conservative and questioning approach to youth gender dysphoria, and concedes that not all youth who experience gender dysphoria will persist with it into adulthood.
Those two documents don’t sit easily side by side. Do No Harm’s letter to the FTC argues that the 2024 policy statement “explicitly endorses medical gender-affirming care and condemns non-affirmation as harmful, while the 2025 FTC submission appears to walk that back in the face of regulatory scrutiny.” It also raises a pointed institutional accountability question, noting that an investigation “must examine why the nation’s largest psychological organization appears to present one face to the public and practitioners and a different face to federal regulators.”
Do No Harm, which describes itself as a conservative medical stakeholder group, penned its letter to FTC Chairman Andrew N. Ferguson, arguing that the APA’s allegedly inconsistent statements could mislead parents and providers in violation of the FTC Act.
Who Is Do No Harm, and What Is the FTC’s Role Here?
Do No Harm describes itself as a group aimed at “protecting healthcare from identity politics.” It is a medically oriented advocacy organization with a clear ideological perspective, which is relevant context for any reader evaluating this story. Its Chief Medical Officer, Dr. Kurt Miceli, has been outspoken on the issue, stating that the APA is “attempting to protect against regulatory action for promoting experimental and dangerous adolescent sex-change interventions, while also staving off anger from the radical gender activists who have captured the organization.”
The FTC is, fundamentally, a consumer protection agency. Section 5 of the Federal Trade Commission Act gives the FTC broad authority to protect consumers from unfair or deceptive acts or practices, and that authority could be implicated if there is evidence that medical professionals or others omitted warnings about risks or made false or unsupported claims about the benefits of gender-affirming care for minors.
The FTC began investigating this area in earnest last summer, shortly after the Trump administration appointed FTC Chairman Andrew N. Ferguson to his post on January 20, 2025. On July 9, 2025, the FTC hosted a workshop titled “The Dangers of ‘Gender-Affirming Care’ for Minors,” focusing on “unfair or deceptive trade practices.” On July 28, the FTC announced a public request for information seeking to evaluate whether minors have been harmed and whether medical professionals may have violated the FTC Act by failing to disclose material risks or making false or unsubstantiated claims about the benefits or effectiveness of gender-affirming care.
A Wider Pattern of Regulatory Scrutiny
The action against the APA doesn’t exist in isolation. In recent months, the FTC launched investigations into whether the World Professional Association for Transgender Health (WPATH), the Endocrine Society, and the American Academy of Pediatrics (AAP) are engaged in deceptive practices regarding pediatric medical transition.
The FTC sent legal demands on January 15, 2026, seeking documents and testimony from the AAP and WPATH as part of a consumer protection investigation into whether the groups made false or unsubstantiated claims related to the marketing or advertising of pediatric gender dysphoria treatment. The Endocrine Society received a similar civil investigative demand on January 20, 2026.
The affected organizations have fought back hard. Two major medical groups filed lawsuits on February 17, 2026, accusing the FTC of launching investigations as part of an effort by the Trump administration to retaliate against them. The American Academy of Pediatrics and the Endocrine Society filed separate lawsuits in federal court in Washington, D.C., challenging the FTC’s demands as an unconstitutional effort to punish them for their support for treating transgender youth.
The AAP lawsuit calls the federal investigation an “unauthorized fishing expedition” into protected speech with which the Trump administration disagrees. The AAP is represented by Covington & Burling LLP and argues the FTC is retaliating against it and discriminating against viewpoints with which it disagrees, in violation of the First Amendment.
The AAP’s position is also grounded in its reading of the science. In responding to a Supreme Court decision over gender-affirming care, AAP President Susan Kressly has said the treatment is “medically necessary for treating gender dysphoria and is backed by decades of peer-reviewed research, clinical experience, and scientific consensus.”
WPATH, for its part, filed a motion to quash the civil investigative demand, arguing that “the FTC lacks authority to issue investigative demands against nonprofits like WPATH, because this investigation violates WPATH’s constitutional rights, and because the CID is overly broad, unduly burdensome, vague, and ambiguous.”
Both sides in this debate are making strong claims. The FTC’s position is that consumer protection law applies equally to medical advocacy, regardless of who the advocacy group is. The medical organizations argue that clinical guidance, even if contested, is protected speech, not deceptive advertising.
The Science Is Genuinely Disputed
For readers trying to make sense of this, the scientific picture on gender-affirming medical care for minors is contested in ways that matter. This isn’t a case where one side has settled consensus and the other has fringe opinions.
Most major U.S. medical associations support youth access to gender-affirming care, including the AAP, the American Medical Association, the American Psychiatric Association, and the Endocrine Society. As of January 2026, twenty-seven states have passed laws or enacted policies that ban or severely restrict access to gender-affirming medical care for transgender youth, with these bans generally prohibiting puberty blockers, hormone therapy, and surgical care for individuals under 18.
On the other side of the ledger, some European health systems that were early adopters of pediatric gender medicine have since pulled back, requiring more rigorous psychological assessment before medical intervention. The APA’s own 2025 letter to the FTC, as described by Do No Harm, appears to gesture in that direction, acknowledging that gender dysphoria doesn’t always persist into adulthood and that the long-term evidence base for medical interventions in minors is still developing.
That acknowledgment, Do No Harm argues, sits in direct tension with a 2024 policy that leaves no room for watchful waiting. The 2024 APA policy statement, as outlined in Do No Harm’s letter, supports gender-affirming procedures for minors, opposes state bans on gender-affirming care for children, and lists “non-affirmation” of a preferred gender as “violence.”
For parents navigating these decisions with their children, the contrast is not academic. It means the professional guidance available to them, and the confidence with which it is delivered, may not reflect the full range of what is scientifically known or unknown.
You may also want to read about how conflicting interests shape U.S. healthcare decisions more broadly, particularly when institutional and patient interests don’t fully align.
What Regulators and Organizations Have Not Yet Said
As of the time of reporting, both the FTC and the APA have not responded to requests for comment on the Do No Harm letter. That silence doesn’t tell us much on its own – regulatory responses take time, and legal strategy often requires organizations to stay quiet before deciding how to respond publicly. But it does mean the story is still in an early stage.
What happens next is genuinely unclear. The FTC’s authority to investigate nonprofit medical organizations is itself being contested in federal court. The Federal Trade Commission issued civil investigative demands to AAP, the Endocrine Society, and WPATH in January 2026, prompting parallel First and Fourth Amendment lawsuits in the U.S. District Court for the District of Columbia. Those cases will likely determine how far the FTC’s consumer protection mandate actually extends into medical guidance.
If the courts ultimately side with the medical organizations, the FTC’s investigation process could be halted before it produces findings. If the courts side with the FTC, it would open up a new and historically unprecedented form of federal oversight over clinical policy statements, with implications that reach far beyond the gender medicine debate.
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What This Means for You
If you are a parent, patient, or caregiver who relies on guidance from major medical organizations, this story raises a practical question worth sitting with: how do you evaluate medical advice when the organizations issuing that advice may be presenting different messages in different contexts?
The answer isn’t to dismiss all expert guidance. The major medical organizations involved in this debate do employ expert clinicians, and their policy positions are built on substantial published research. But the APA’s apparent willingness to say different things to the public and to a regulator, if Do No Harm’s characterization is accurate, is a reminder that institutional positions are shaped by more than science alone. Politics, advocacy priorities, and liability considerations all play a role.
For families with children experiencing gender dysphoria, the most protective thing you can do is seek out providers who are willing to engage in thorough, individualized psychological assessment rather than applying a one-size-fits-all approach in either direction. Even the APA’s own 2025 regulatory submission reportedly acknowledged that not all youth who experience gender dysphoria will persist with it into adulthood, which suggests that time, assessment, and individualized care matter. That’s something every informed parent and patient should keep in mind as this legal and regulatory story continues to unfold. If this case ultimately redefines how medical organizations communicate with the public versus regulators, the ripple effects will extend well beyond gender medicine and into how we evaluate expert guidance across every area of health.
AI Disclaimer: This article was created with the assistance of AI tools and reviewed by a human editor.
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