The Wolves Finally Got Caught

By Jay Rogers

I have spent over three decades in wealth management and testifying as an expert witness on fiduciary duty, which boils down to one idea: when you are entrusted with someone else's well-being, you do not get to profit from betraying it. Doctors call their version of that rule “First, do no harm.” On August 13, the Department of Health and Human Services released a report suggesting a lot of doctors and hospitals forgot they ever took that oath.

The report is titled “Wolves in White Coats: How Doctors and Hospitals Pushed and Profited from the Fraud of ‘Gender Medicine,’” and the title alone tells you HHS did not commission it to win a Pulitzer for restraint. According to HHS, more than 225 hospitals and health systems built pediatric gender programs over the past decade, and the department's claims analysis found roughly $50 million in insurance billing for puberty blockers between 2015 and 2025 run through an unspecified endocrine-disorder code rather than a gender dysphoria diagnosis. Another $11 million in claims for teenagers ages 13 to 17 went through E30.1, the precocious-puberty code meant for children whose bodies are maturing years ahead of schedule, not adolescents starting hormone blockers for gender distress. HHS Secretary Robert F. Kennedy Jr. and Vice President J.D. Vance, who chairs the White House Fraud Task Force, referred the identified hospitals and clinics to the Department of Justice and the HHS Inspector General, the kind of referral that in my expert witness work usually precedes subpoenas for the full billing history, not just the sample the report examined.

Let's be clear about what a referral is and is not. It is not a verdict. Whether any specific hospital committed civil or criminal fraud depends on the medical record, the coding guidance in effect at the time, payer rules, and intent, and that gets sorted out by investigators and courts, not press releases. I have sat in enough depositions to know that headlines and legal findings are different animals. But I have also read enough billing files in my career to know that when an industry routes tens of millions of dollars around diagnostic codes to avoid scrutiny, that pattern didn’t happen by accident. Coding departments do not misfile at scale. They optimize.

And optimizing is exactly what you would expect once you follow the incentive. A gender dysphoria diagnosis on a 9-year-old's chart invites review. An unspecified endocrine disorder does not. HHS calls these children “captive patients,” and if you have ever worked in healthcare finance, as I did briefly at UCLA Medical Center in the early 1990s, you already know what that phrase means. A patient started on puberty blockers as a child is a patient positioned for a lifetime of cross-sex hormones, follow-up visits, and eventually surgical referrals. Gordon Gekko told us greed is good because it “clarifies, cuts through, and captures the essence.” He was talking about corporate raiders, not pediatric endocrinology, but the line works uncomfortably well here.

The counterargument I hear most often, usually from people who mean well, is that gender-affirming care is settled medical consensus, and this report is a partisan hit job dressed up as an audit. I would take that more seriously if the U.K.'s own National Health Service had not already reached similar conclusions. The Cass Review, the four-year independent review commissioned by NHS England and led by pediatrician Hilary Cass, found the evidence behind both medical and non-medical interventions for gender-distressed youth to be weak, concluded that clinicians cannot reliably predict which children will carry a trans identity into adulthood, and recommended that puberty blockers be available only inside a formal research protocol. Britain's own regulator rated the Tavistock's Gender Identity Development Service “inadequate” after whistleblowers raised safeguarding concerns, and the NHS shut that clinic down in 2024 and rebuilt the entire model around caution and individualized psychiatric assessment before any medical pathway. When the British health system and a Trump-era HHS report land on the same conclusion from opposite sides of the Atlantic, you are not looking at a conspiracy. You are looking at data catching up to ideology.

I say this as someone raised Catholic, married into a Jewish family, and about as allergic to religious dogma as I am to political dogma. This was never a fight about faith. It is a fight about biology and about basic professional ethics. XX and XY are not lifestyle preferences; they are chromosomes and biological facts. No committee language from a medical association changes that fact any more than a committee vote could change the value of pi. When the adults entrusted with a child's care start treating that child's confusion as a revenue opportunity, the moral math is not complicated, whatever the billing code says.

None of this means every family who pursued this care was defrauded, and none of it should be used to demonize parents who trusted the professionals in front of them. That trust is precisely what got exploited. The fix is not complicated. Insurers and state Medicaid programs should require gender-related diagnostic codes to match the actual treatment billed, full stop, with real audits and real penalties for mismatches. Congress should make permanent the ban on taxpayer funding for pediatric medical transition that the Trump administration has already started enforcing through the Centers for Medicare and Medicaid Services. And state medical boards, not just federal prosecutors, need to ask why so many of their licensees found their way to the same lucrative diagnosis pattern at the same time.


I have coached teenagers for many years, in weight rooms, on the rugby pitch, and on the track, and the one thing I know about kids that age is they change their minds constantly. That is what being 13 is. Building a medical-financial pipeline around the assumption that they will not change their minds was never science. It was a business model wearing a lab coat, and it took federal investigators to finally read the invoice.

Jay Rogers is a financial professional with more than 30 years of experience in private equity, private credit, hedge funds, and wealth management. He has a BS from Northeastern University and has completed postgraduate studies at UCLA, UPENN, and Harvard. He writes about issues in finance, constitutional law, national security, human nature, and public policy.