January 20, 2026

NHeLP Comments on 2025 Proposed Section 504 changes

By: Jennifer Lav, Abigail Coursolle, and Carly Myers

Executive Summary

NHeLP comments strongly opposing HHS’ proposal to exclude gender dysphoria from the definition of disability, because it is inconsistent with congressional intent; inconsistent with the plain language of Section 504; and motivated by discriminatory animus.

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NHeLP Comments on 2025 Proposed Section 504 changes

Executive Summary

Related Content

NHeLP Comments on Proposed Rules on Gender-Affirming Care

LGBTQ+ Unwinding Fact Sheets for Medi-Cal and Medicaid

National Health Law Program Comments on the DEA’s Proposed Rule on Telemedicine Prescribing of Controlled Medications