The Human Rights Campaign Foundation launched a class-wide discrimination challenge on Thursday to a new Office of Personnel Management (OPM) policy that eliminates health-insurance coverage for most gender-affirming medical care in the Federal Employees Health Benefits (FEHB) and Postal Service Health Benefits (PSHB) programs, alleging that the change violates Title VII’s ban on sex discrimination in employment.

The filing was brought on behalf of a proposed class of similarly situated federal workers and targets OPM’s policy instructing all participating FEHB and PSHB carriers that, beginning in the 2026 plan year, “chemical and surgical modification” of an individual’s sex traits through medical interventions, including services associated with “gender transition,” will no longer be covered under federal employee health plans. The directive applies across all ages and expands on earlier guidance.

OPM’s letter requires carriers to maintain coverage for counseling related to gender dysphoria and to establish a narrow, case-by-case “exceptions process” for beneficiaries who are already mid-treatment in a surgical and/or hormonal regimen when the exclusion takes effect. The complainants contend that this exception is both opaque and unduly restrictive, particularly for enrollees who must change plans for 2026, and does not cure what they describe as a categorical exclusion of medically necessary gender-affirming care.

The filing alleges two related theories of discrimination. First, it claims that OPM’s blanket exclusion of surgical and hormonal interventions for gender transition facially discriminates based on sex and transgender status because it targets a course of treatment that only transgender people and those with gender dysphoria are likely to need. Second, the filing argues that the separate “exceptions” track for people already in treatment further entrenches discriminatory treatment by forcing transgender employees and their dependents uniquely to justify continuation of care that non-transgender enrollees may receive without any comparable hurdle.

The class representatives seek rescission of Carrier Letter 2025-01b and any related policy changes, a declaration that the exclusion is unlawful both on its face and as applied to the named complainants and the class, and a directive requiring all FEHB and PSHB plans to strip any discriminatory exclusions for gender-affirming care from their 2026 plan documents. They also propose that every plan brochure include a plain-language nondiscrimination clause making clear that coverage decisions will not turn on a member’s gender identity or the fact that a treatment is needed in connection with gender-affirming care.

Major medical organizations, including the American Medical Association, the American Academy of Pediatrics, and the American Psychological Association, have consistently endorsed gender-affirming care as evidence-based and medically necessary for many transgender patients. The complainants rely on this medical consensus to argue that OPM’s exclusions cut off standard treatment for a diagnosed condition that is covered when provided for other indications.