Out-of-state conservative activists have for years played a prominent role in pushing Utah to pass restrictions on gender-affirming care for transgender youth.
But after a Legislature-commissioned report concluded in May that such treatments largely result in positive outcomes and reduce suicidality, national advocacy groups on the right appear to be investing more in casting doubt on the science supporting gender-affirming care.
Led by the group Do No Harm, those outside efforts feature some of the same activists President Donald Trump has relied on to shape his own anti-transgender policies.
Speaking on the House floor last week, Rep. Rex Shipp, R-Cedar City, criticized the Utah study provided to the Legislature.
“This report, done by the Utah Department of Health and Human Services, is a flawed report with significant bias,” Shipp told his colleagues as he discussed HB174, the bill he’s sponsoring to further restrict access to hormone therapy. They voted 54-15 to send it to the Senate.
Shipp cited two outside reports that took aim at the credibility of the Utah review — one by the U.S. Department of Health and Human Services, written by prominent anti-transgender activists, and another from Do No Harm, an advocacy group formed to lobby for bans on gender-affirming care.
A revised version of the U.S. Department of Health and Human Services report, published in November, said the findings in Utah’s review are “without sound methodological basis.” The next month, Do No Harm issued its own criticism, called, “Debunking the Utah Department of Health and Human Services’ Defense of Pediatric Medical Transition.”
Utah currently has a “moratorium” on gender-affirming care for transgender youth, under a law introduced by now-U.S. Rep. Mike Kennedy during his time as a state senator. The law prohibits surgically changing a transgender minor’s sex characteristics and bars prescribing puberty blockers or hormone replacement therapy to Utahns under 18 who were not diagnosed with gender dysphoria prior to the 2023 bill being signed into law.
Shipp’s HB174 would impose more permanent restrictions on transgender youth access to hormone therapy, with limited exceptions for minors already receiving that care.
If the Senate approves the proposal, and absent a veto, it could make this the fifth consecutive year Utah has adopted a law restricting the rights of its transgender residents.
For Utah’s report, the University of Utah’s Drug Regimen Review Center compiled the medical evidence under a contract with Utah’s DHHS, which gave researchers a $150,000 budget. Ahead of submitting the thousand-page report, experts sifted through 277 studies — which included more than 28,000 pediatric patients around the world — that met the standards for consideration.
They wrote that research indicates gender-affirming hormone treatments to alleviate gender dysphoria are effective and carry little risk. The pharmacists who read the studies and compiled the review added that, in their opinion, there is no evidence to justify policies that prevent access to gender-affirming care for transgender minors.
And a more limited analysis of research on the long-term effects of hormone treatment, included at the end of the report, said transgender adults who were able to access gender-affirming care before age 18 “had a lower risk of suicide compared to those referred as an adult.”
That aligns with the consensus of most major medical groups in the U.S., including the American Medical Association, the American Academy of Pediatrics, the Endocrine Society, the American Psychological Association and the American Psychiatric Association.
“I know that there is a tendency to say that ‘I can vote for this bill because the science is behind it,’” said Rep. Jennifer Dailey-Provost, R-Salt Lake City, on the House floor, “and I’m here to tell you why it is not.”
Dailey-Provost, who also works as a public health researcher and instructor at the University of Utah, told representatives, “Denying health care to a very marginalized, at-risk population of children is always going to be a mistake. My views on that have been clear. But I also am really, really distressed that we’ve allowed bad science to be reasoning for bad legislation.”
Since receiving the medical evidence review in May, lawmakers have not held a public discussion on it, nor have they given time to researchers or DHHS officials to present its conclusions.
Do No Harm
“Would you consider covering?” read a December email to reporters, with Do No Harm’s memo challenging Utah’s medical evidence review. The public relations firm said the document, which was fewer than 10 pages, “outlines the errors in a report that seemingly aims to persuade the Utah State Legislature to allow hormonal interventions for minors with gender dysphoria.”
The marketing firm that sent the dispatch was CRC Advisors. It sent another in January urging journalists to report on two Do No Harm representatives testifying in a committee hearing for Shipp’s bill “to protect children from sex-rejecting interventions.”
Leonard Leo is one of four beneficial owners of CRC Advisors, according to business records filed with the Department of Licensing and Consumer Protection for Washington, D.C. The longtime legal activist is best known for his influence securing nominations and confirmations of conservative justices to the U.S. Supreme Court.
Since the addition of those justices, the court has shifted to largely deciding in favor of arguments from the political right, including in its ruling in United States v. Skrmetti upholding a Tennessee ban on gender-affirming care for minors.
Do No Harm filed an amicus brief in the case several months ahead of the decision.
An image of the organization’s Chair Stanley Goldfarb at the White House is the cover of its most recent annual report, which called 2025 “a year of remarkable victories for Do No Harm.”
“Most notably,” the report continued, “we provided the administration with the data and resources needed throughout the year to inform groundbreaking executive orders.”
Two of the organization’s employees — Chief Medical Officer Kurt Miceli and senior fellow Chloe Cole — helped Shipp present his bill to the House Health and Human Services Committee last month.
Cole is a Californian who publicly identifies herself as a “detransitioner,” or someone who began transitioning to another gender and decided to transition back. She also testified in front of Utah lawmakers when they weighed the current gender-affirming care moratorium in 2023.
When she took the stand in a lawsuit over a gender-affirming care ban in Ohio in 2024, Cole told an attorney for the American Civil Liberties Union that she makes six figures annually for advocating for bans — about $2,000 a month from Do No Harm for testifying in front of state legislatures, between $50,000 and $100,000 in speaking fees, and another $100,000 in donations from supporters.
The conservative activist organization that employs Cole reported in documents filed with the IRS that it spent over $600,000 lobbying legislative bodies from 2022 to 2024.
Its political arm, Do No Harm Action, reported spending $1.5 million on lobbying from its inception in 2023 through the end of 2024. That entity said it paid another million dollars to August Strategy Group LLC for advocacy and consulting — the two lobbyists that have registered in Utah to represent Do No Harm are employed by that company.
Nonprofits are only required to disclose donors on a limited basis. But among the names that do appear on Do No Harm’s IRS filings are larger conservative activist groups that have a lengthy track record of backing anti-transgender messaging: Family Policy Alliance Foundation and The Heritage Foundation.
The latter organized the drafting and published the controversial Project 2025 playbook in anticipation of Trump’s electoral victory, which encouraged measures rolling back transgender rights and narrowing access to gender-affirming care.
Behind the Trump administration’s report
When the White House released its own report on treating gender dysphoria in minors last May, the authors were initially anonymous. The federal government published a revised version in November that revealed the writers — well-known opponents of gender-affirming care.
The updated version criticized Utah’s medical evidence review, alleging, “this review lacks a methodologically valid evidence appraisal, among other problems.”
Some of the names listed as contributors are familiar to Utah lawmakers.
One, Leor Sapir, has appeared alongside GOP legislators opposing gender-affirming care on multiple occasions. He works as a senior fellow at the conservative public policy think tank Manhattan Institute and his academic background is in political science.
The Manhattan Institute and Do No Harm share Utah lobbyists, according to a lobbyist registration database maintained by the lieutenant governor’s office. In its 2024 report, The Manhattan Institute said it had found “receptive ears” in presenting proposals to Trump’s transition team.
“On Day One of his second administration, President Trump issued executive actions to eliminate all federal DEI offices, programs, and grants, and he revoked Biden-era executive orders on racial and gender equity. This sweeping action reflected the research and journalism of MI scholars Rufo and Leor Sapir,” the annual report said. “Despite this progress, identity politics remains entrenched in the federal government, and MI scholars have redoubled their efforts to see it fully dismantled.”
Sapir joined Cole next to Kennedy in 2023 when he asked colleagues to pass the care moratorium, and over a year later appeared in front of an interim committee Kennedy chaired to give input on transgender health policies as state officials gave an update on the moratorium.
Sapir characterized comments on the high suicide rates for youth with gender dysphoria — for which the treatment is typically gender-affirming care — as “emotional blackmail” in a 2023 hearing. Pediatrician and state Sen. Jennifer Plumb, D-Salt Lake City, pointed out in response that his background does not include medical expertise.
Another author of the Trump administration’s report, Michael Laidlaw, was repeatedly quoted in a handout Shipp gave to colleagues when he first tried to pass a gender-affirming care ban in 2021. When testifying on proposed legislation in South Dakota, Laidlaw compared gender-affirming care to Nazi eugenics.
If Shipp had been successful, Utah would have been the first state in the country to pass a ban. It ultimately became the fourth in what has become a majority of states banning gender-affirming care.
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