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........

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