In July 2025, the United States Department of Justice (“DOJ”) announced that it had issued “more than 20 subpoenas” to health care providers involved in the provision of gender-affirming care to minors. On August 18, 2025, one of these subpoenas—issued to a children’s hospital in Pennsylvania (the “Hospital”)—was included in a court filing that became public (the “Subpoena”).
The Subpoena demanded that the Hospital produce extensive documentation from the period ranging from January 1, 2020, to the date of the Subpoena. Requests included, but were not limited to:
- Complete personnel files for (i) all executives, management employees, and board members, (ii) employees, contractors, and affiliates authorized to prescribe medications or perform medical evaluations, and (iii) employees, contractors, and affiliates engaged in billing activities;
- Guidance, documentation, and communications related to coding and billing of gender-affirming care;
- Correspondence and contracts with, and other materials related to, manufacturers and/or compounders of puberty blockers or hormones;
- Documentation identifying each patient—including name, date of birth, Social Security number, address, and parent/guardian information—who was prescribed puberty blockers or hormone therapy; and
- Documents regarding informed consent, adverse events, and safety of puberty blockers and hormones.
The Subpoena was included in a court filing related to ongoing litigation involving Executive Order 14187 (the “Executive Order”). The Executive Order set forth Trump administration policies opposing the provision of gender-affirming care to minors and directed agencies and certain federal health care programs to limit access to such care through measures such as halting federal grant funding to medical institutions that provide gender-affirming care to minors. Enforcement of the Executive Order is currently enjoined. (See our previous alert on the Executive Order here, and our alert regarding the ongoing litigation related to the Executive Order here.)
Of note, provision of gender-affirming care to minors is lawful in Pennsylvania, where the Hospital is located, and such care was not legally prohibited in any state as of January 1, 2020, when the Subpoena’s period of concern begins. This underscores the Trump administration’s stated intent to use federal resources to curtail provision of gender-affirming care to minors—even in states where such care is permitted or protected by state law or regulation.
Practical Takeaways
- Stay Informed: Continue to check Hall Render’s website for updates on DOJ and agency action, as well as related information regarding provision of gender-affirming care to minors.
- Communicate: Maintain open communication with providers and clinical leadership to ensure all parties are aware of ongoing legal challenges to the provision of gender-affirming care to minors and how such challenges may affect their practices.
- Work Closely with Counsel: Work with legal counsel to appropriately assess risk associated with provision of care that may fall within the scope of the Executive Order and/or state laws that conflict with it.
If you have questions regarding the subpoenas, the Executive Order, the associated litigation, or state law governing provision of gender-affirming care to minors, please contact:
- Jennifer Skeels at jskeels@hallrender.com or (317) 977-1497;
- Cait Bell-Butterfield at cbell-butterfield@hallrender.com or (919) 228-2408; or
- Your primary Hall Render contact.
Hall Render blog posts and articles are intended for informational purposes only. For ethical reasons, Hall Render attorneys cannot—outside of an attorney-client relationship—answer specific questions that would be legal advice.
