Does Medicare Cover Gender-Confirmation Surgery?

Medicare determines coverage for gender-confirmation surgery, also known as gender affirmation surgery, on a case-by-case basis. It has not issued a federal rule for this procedure or for gender dysphoria-related hormone therapy. If your request for this surgery is denied, you can appeal the decision.

Rachel Christian, writer and researcher for RetireGuide
  • Written by
    Rachel Christian

    Rachel Christian

    Financial Writer and Certified Educator in Personal Finance

    Rachel Christian is a writer and researcher for RetireGuide. She covers annuities, Medicare, life insurance and other important retirement topics. Rachel is a member of the Association for Financial Counseling & Planning Education.

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    Matt Mauney
    Matt Mauney, Senior Editor for RetireGuide

    Matt Mauney

    Financial Editor

    Matt Mauney is an award-winning journalist, editor, writer and content strategist with more than 15 years of professional experience working for nationally recognized newspapers and digital brands. He has contributed content for ChicagoTribune.com, LATimes.com, The Hill and the American Cancer Society, and he was part of the Orlando Sentinel digital staff that was named a Pulitzer Prize finalist in 2017.

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  • Published: March 8, 2021
  • Updated: September 15, 2022
  • 4 min read time
  • This page features 6 Cited Research Articles
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APA Christian, R. (2022, September 15). Does Medicare Cover Gender-Confirmation Surgery? RetireGuide.com. Retrieved September 29, 2022, from https://www.retireguide.com/medicare/treatments/surgery/gender-confirmation-surgery/

MLA Christian, Rachel. "Does Medicare Cover Gender-Confirmation Surgery?" RetireGuide.com, 15 Sep 2022, https://www.retireguide.com/medicare/treatments/surgery/gender-confirmation-surgery/.

Chicago Christian, Rachel. "Does Medicare Cover Gender-Confirmation Surgery?" RetireGuide.com. Last modified September 15, 2022. https://www.retireguide.com/medicare/treatments/surgery/gender-confirmation-surgery/.

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What Is Gender-Confirmation Surgery?

Gender-confirmation surgery, also known as gender affirmation surgery, is one or more surgical procedures in which a transgender person’s physical appearance and function of their sexual organs are altered to resemble those of their identified gender.

According to a 2022 article from the National Library of Medicine, gender-confirmation surgery has been increasingly performed over the last five years, and has been shown to improve quality of life for those experiencing gender dysphoria.

Gender-confirmation surgeries are typically divided into two broad categories: Top surgeries and bottom surgeries.

Two Categories of Gender-Confirmation Surgery
Top Surgeries
For female to male, top surgery involves removing breast tissue and flattening the chest. For male to female, it involves breast augmentation.
Bottom Surgeries
There are multiple types of bottom surgeries. For female to male, phalloplasty and metoidioplasty are used to construct a penis. Other surgeries are used to construct a scrotum. For male to female, vaginoplasty and penile inversion procedures are used to construct a vagina.

These surgeries can be expensive, carry health risks and complications, and may involve follow-up medical care and procedures. Speak with your doctor to learn more and to develop a plan of care.

Many transgender people choose to practice hormone therapy. You may need to do so for your gender-confirmation surgery to be considered medically necessary.

Common Hormone Replacement Therapy
Estrogen Therapy
This is used for people transitioning from male to female. During feminizing hormone therapy, you are given medication to block testosterone. You are also given estrogen to decrease testosterone production and induce feminine secondary sex characteristics.
Testosterone Therapy
This is used for people transitioning from female to male. During masculinizing hormone therapy, you are given testosterone, which suppresses your menstrual cycle and decreases the production of estrogen from your ovaries.
Surgeries Covered Under Medicare

Medicare Coverage of Gender-Confirmation Surgery

Medicare did not cover transition-related surgery for many years because it categorized such operations as experimental.

That exclusion was eliminated in 2014.

In 2016, the Centers for Medicare & Medicaid Services, or CMS, decided that local Medicare Administrative Contractors can determine coverage of gender-confirmation surgery on a case-by-case basis.

CMS chose not to issue a wider National Coverage Determination for gender-confirmation surgery, according to a 2016 decision memo, because the clinical evidence was “inconclusive for the Medicare population.”

Likewise, CMS has not made a National Coverage Determination for gender dysphoria-related hormone therapy or other potential treatments.

Local administrators decide whether to cover gender-confirmation surgery based on whether the operation is “reasonable and necessary” for the beneficiary after considering the person’s specific circumstance.

For Medicare Advantage beneficiaries, each Medicare Advantage plan is responsible for determining whether surgery is reasonable and necessary.

Medicare does not cover certain cosmetic surgery procedures, such as laser hair removal and facial feminization surgery, because these are not considered medically necessary.

Even if Medicare covers your gender-affirmation surgery, you will still face out-of-pocket costs, such as deductibles and coinsurance payments.

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Determining If a Procedure Is Reasonable and Necessary

According to the CMS decision memo, physician recommendations are one of many potential factors that local Medicare administrators may consider when deciding whether documentation is sufficient to pay a claim.

The best way to find out if your gender-confirmation surgery is covered is by speaking with your doctor or Medicare plan provider.

What If Your Surgery Is Denied?

Because transition-related surgery is decided on a case-by-case basis, your request may be denied.

However, if you and your doctor believe the surgery is reasonable or medically necessary, you can appeal Medicare’s decision.

Original Medicare beneficiaries can fill out a Redetermination Request Form to appeal. Medicare has 60 calendar days to respond.

Medicare Advantage beneficiaries must directly contact their plan provider to appeal. Medicare Advantage plans have 30 to 60 calendar days to make a decision on your case.

Organizations such as the National Center for Transgender Equality highly recommend that beneficiaries consult with a lawyer before filing an appeal.

You can appeal Medicare’s decision up to four times after your first appeal.

Last Modified: September 15, 2022

6 Cited Research Articles

  1. Merrick, E. & et al. (2022, June 13). National Trends in Gender-Affirming Surgical Procedures: A Google Trends Analysis. Retrieved from https://www.ncbi.nlm.nih.gov/pmc/articles/PMC9278897/
  2. Mayo Clinic. (2020, April 14). Feminizing hormone therapy. Retrieved from https://www.mayoclinic.org/tests-procedures/feminizing-hormone-therapy/about/pac-20385096
  3. Mayo Clinic. (2020, April 14). Masculinizing hormone therapy. Retrieved from https://www.mayoclinic.org/tests-procedures/masculinizing-hormone-therapy/about/pac-20385099
  4. Mayo Clinic. (2017, September 26). Feminizing surgery. Retrieved from https://www.mayoclinic.org/tests-procedures/feminizing-surgery/about/pac-20385102
  5. Centers for Medicare & Medicaid Services. (2016, August 30). Decision Memo for GENDER Dysphoria and GENDER REASSIGNMENT SURGERY (CAG-00446N). Retrieved from https://www.cms.gov/medicare-coverage-database/view/ncacal-decision-memo.aspx?proposed=N&NCAId=282&CoverageSelection
  6. National Center for Transgender Equality. (n.d.). What Does Medicare Cover for Transgender People? Retrieved from https://transequality.org/know-your-rights/medicare