As more employers recognize the importance of promoting workforce diversity and inclusion, many have taken steps to close gaps in health coverage for transgender individuals. This is also important from a compliance perspective, since gender dysphoria is a defined diagnosis and a transgender individual with this diagnosis has a mental health condition that requires treatment.
Some employers may hesitate to act because of concerns that covering transgender individuals will “open a Pandora’s box” of claims and that all services must be covered. However, the World Professional Association for Transgender Health (WPATH) has published standards of care established from evidence-based clinical guidelines that articulate an appropriate range of healthcare services for transgender individuals. Also, the number of individuals who have gender dysphoria or undergo gender reassignment treatment is very low. An employer can expect one to two claimants for every 10,000 employees. Moreover, gender dysphoria treatment ranges from mental health counseling to gender reassignment surgery and includes ancillary procedures such as body and face feminization/masculinization. Not everyone who has gender dysphoria will choose to go through the complete transition journey. If someone decides in conjunction with his or her doctors that surgery is necessary, the cost of care is usually spread out over a number of years.
Here are steps employers can take to ensure their benefit programs meet the needs of transgender individuals:
- Verify coverage of services for transgender individuals. This can be done through a questionnaire to the technical/medical area of the carrier and should include a review of the carrier’s clinical policies to ensure adherence to the WPATH standards. Some health plans specifically exclude any service for transgender individuals, which can raise serious concerns regarding potential noncompliance with mental health parity requirements.
- Conduct an assessment of the health plan’s clinical policies. Even if a plan says it uses the WPATH standards as its clinical guidelines, it may not be in full compliance. Employers may want to conduct an assessment to ensure a plan’s clinical policies are aligned with the WPATH standards for healthcare services, equipment, and supplies. This assessment can identify gaps and help establish minimum standards tailored to a company’s appetite for inclusiveness, budget and risk tolerance.
- Listen to your transgender employees through employee resource groups or other methods. This could provide anecdotal and qualitative information on how to improve healthcare experiences for transgender individuals.
- Identify a center of excellence (COE) for healthcare services for transgender individuals.
- Maintain a provider directory with indicators of competency in treatment for transgender individuals.
- Create a dedicated transgender services team at the health plan.
Employers realize that in order to attract and retain talent, they need an inclusive work environment. For LGBTQ employees, the Human Rights Campaign Corporate Equality Index, which includes criteria for workforce protections and benefits, provides the strongest evidence of commitment. Customers and clients may expect companies to be sensitive to the needs of the LGBTQ community as well. And other stakeholders, such as investors and board members, are likely to be looking for demonstrations of a meaningful commitment to diversity and inclusion.
Authors: Diego Ramirez M.D., Global Inclusive Benefits Product Lead & Michael Garret, MS, CCM