Two Planned Parenthood facilities in Pennsylvania have been publicly describing a billing practice that health experts say amounts to insurance fraud, coding cross-sex hormone prescriptions under a diagnosis for endocrine disorders rather than gender identity conditions, a move that makes it easier to secure coverage from insurers and Medicaid.
The practice, laid out on the organizations' own websites, has drawn sharp criticism from physicians who testified before the Federal Trade Commission in July 2025 and from a medical watchdog group that published a detailed report this year. Their charge is straightforward: Planned Parenthood is slapping a false medical diagnosis on physically healthy patients to get insurance companies to pay for treatments those companies might otherwise deny.
And taxpayers are funding the organizations doing it. Between July 2020 and June 2025, Planned Parenthood of Southeastern Pennsylvania received more than $10.7 million in taxpayer funds, while Planned Parenthood of Western Pennsylvania took in more than $4.1 million, according to nonprofit tax filings reviewed by ProPublica.
The billing guidance isn't hidden. It's posted on Planned Parenthood's own FAQ and services pages, and it has been for years.
Planned Parenthood of Western Pennsylvania's billing guidance has been live on its website since at least January 2021. The southeastern Pennsylvania affiliate's version has been posted since at least February 2023, as the Washington Examiner reported.
The southeastern Pennsylvania facility's FAQ page states plainly how it handles billing for cross-sex hormones:
"In order to meet the needs of most insurance companies and patients, we typically use the code E34.9 (endocrine disorder, unspecified) and occasionally will use F64.9 (gender identity disorder, unspecified) if necessary."
That same page offers a candid explanation of why. The facility says it recognizes "that much of the language around billing for gender affirming care is troublesome" and pledges to "decrease barriers to getting folks the care they need."
The western Pennsylvania affiliate includes its own disclaimer on its fees and services page:
"Note that while we don't like the wording used in many of these codes, they are used by insurers and medical billers on a national basis and we are unfortunately required to keep the wording the same when using them because of that."
Neither facility responded to the Washington Examiner's requests for comment.
The ICD-10 coding system, maintained by the World Health Organization, is the backbone of medical billing in the United States. Insurance providers rely on ICD codes to determine whether a treatment is covered. Code E34.9 designates an "endocrine disorder, unspecified." Code F64.9 designates a "gender identity disorder, unspecified."
The distinction matters enormously. A patient prescribed cross-sex hormones for a gender identity condition is not suffering from an unspecified endocrine disorder. By using E34.9, critics say, Planned Parenthood is misrepresenting the reason for treatment to make the claim more likely to be approved.
Dr. Kurt Miceli, a physician affiliated with the medical group Do No Harm, laid out the problem in an April report that specifically called out the southeastern Pennsylvania facility's coding practices. Miceli wrote:
"Utilizing these 'alternative' codes is misleading and contrary to the ICD-10-CM Official Guidelines for Coding and Reporting, which requires providers to '[c]ode to the highest level of specificity when supported by medical record documentation.'"
In other words, when a provider knows exactly why a patient is seeking treatment, gender transition, coding it as a vague endocrine problem violates the rules that govern medical billing nationwide.
Dr. Miriam Grossman drove the point home during her July 2025 testimony before the FTC:
"These are physically healthy people. They have no medical diagnosis whatsoever. They have a psychiatric diagnosis. But this E34.9 is being used in a fraudulent way, I would say, in order to get payment for the services."
Pennsylvania isn't the first state where this billing pattern has surfaced. Texas Attorney General Ken Paxton has been pursuing legal action against sex-change doctors and health institutions since whistleblowers came forward in 2023.
Dr. Eithan Haim, a Texas surgeon, first raised the alarm that year over what he described as secret child sex-changes at Texas Children's Hospital. Paxton's subsequent investigation found that Texas Children's Hospital used false diagnosis codes to transition children, among other legally questionable actions. The hospital entered a civil settlement with the Texas attorney general's office and the U.S. Department of Justice in May.
One Texas physician surrendered her medical license in October 2025 after Paxton sued her. In a separate December filing against another doctor, Paxton's office stated that "gender activist organizations" openly encourage health providers to use misleading diagnoses to secure coverage.
Haim described the billing scheme in blunt terms. He told the Washington Examiner that providers have invested enormous effort in finding which ICD codes can justify gender interventions "under a false pretense without pushback from insurance companies."
He pointed to a grim irony at the center of the practice:
"They're actually inducing the disorder that they're claiming to treat. Once they're started on hormones and all that s***, they have an endocrine disorder, but it was just one that was given to them by their doctors."
Haim did not hold back about the legal implications. He said that in any other medical specialty, "these people would be going to prison." He described the practice as "a level of criminality in healthcare fraud that has never been even described", creating the disease used to justify the treatment that created the disease in the first place.
Haim said he is currently helping government officials investigate fraud in the sex-change industry, though he declined to discuss specifics. Both Miceli and Grossman testified before the FTC in July 2025, bringing the coding issue directly to a federal regulatory body.
But the Pennsylvania situation raises questions that remain unanswered. No formal complaint, investigation, or legal action against the two Pennsylvania Planned Parenthood facilities has been publicly disclosed. It is unclear which specific insurers or Medicaid programs have been billed using the E34.9 code at these locations. The total number of patients affected and claims submitted under the disputed code is unknown.
It is also unclear whether the practice at these facilities applies to adult patients, minor patients, or both. Sex changes for minors remain legal in Pennsylvania.
The $10.7 million and $4.1 million in taxpayer funds the two affiliates received over five years, documented in IRS Form 990 filings, represent total government revenue, not necessarily Medicaid reimbursements tied to the disputed billing code. But the scale of public funding underscores the stakes. If the coding practice does constitute fraud, taxpayers may be on the hook for treatments obtained under false pretenses at facilities they are already subsidizing.
What makes the Pennsylvania situation unusual is how openly the practice has been described. These aren't leaked internal memos or whistleblower allegations about hidden conduct. Planned Parenthood posted the billing guidance on its public-facing websites, where it has remained for years. The southeastern Pennsylvania FAQ has been live since at least February 2023. The western Pennsylvania version dates to January 2021.
The facilities acknowledge the coding language is imperfect. They frame their approach as patient advocacy, removing barriers to care. But the ICD-10 coding guidelines exist for a reason. They prevent providers from misrepresenting a patient's condition to secure payment. When a clinic tells an insurer that a patient has an "endocrine disorder, unspecified" in order to get cross-sex hormones covered, and the patient's actual condition is a gender identity diagnosis, the gap between what is billed and what is true is not a technicality. It is the definition of a false claim.
Texas has already shown what happens when investigators follow this trail. A major children's hospital settled with state and federal authorities. A physician lost her license. Legal filings multiplied.
Pennsylvania's Planned Parenthood affiliates have been advertising the playbook on their own websites for years. The only remaining question is whether anyone with enforcement authority plans to read it.
