Effective October 1, 2025, the US Department of Health and Human Services (HHS) implemented grants policy statement (GPS) v2.0, consistent with its prior adoption of 2 CFR part 200 with HHS-specific provisions at 2 CFR part 300. Separately, the Health Resources and Services Administration (HRSA) published a strategic priority areas memorandum stating that, subject to applicable law and court orders, HRSA will deprioritize programs that engage in certain medical interventions for minors with gender dysphoria, and HRSA funds will not support the costs of those practices.
In practice, “deprioritize” has two dimensions: lower competitiveness in discretionary selections and a likelihood that such costs will be treated as unallowable under the terms of award. A nationwide preliminary injunction (PFLAG v. Trump) and a four-state preliminary injunction (Washington v. Trump) currently prohibit HHS/HRSA from punishing recipients because they provide gender-affirming care (GAC) to people under age 19, but the injunctions do not convert costs that are identified as not supported in the award into allowable charges.
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