To receive credit in the CEI, a company must:

• Answer “yes”
• Upload a copy of the summary plan description (or summary material modification) that explicitly affirms coverage for transition-related care.
• Upload a copy of the applicable clinical guidelines (also called a medical policy).

To receive credit in the CEI, a company must:

• Upload a copy of a summary plan description (or summary material modification) that explicitly affirms coverage of transition-related care.

More information:

• A summary plan description is a document that tells the plan participant (employee) that their specific plan provides and how it operates. For self-insured plan sponsors (employers), this document is unique to the organization.
• Covered benefits must include
  • Mental health counseling
  • Hormone replacement therapy
  • Routine doctor’s visits and lab testing
  • Surgical procedures
  • Paid short-term leave (whether employer
    provided or employer purchased)

Examples:

• Dana-Farber Cancer Institute's plan through Harvard Pilgrim Healthcare outlines the covered health services for transgender employees, along with other important information about obtaining coverage.
• UNC Health's plan details the different treatments for gender dysphoria that are covered by their plan.

Note: In order to receive credit, your company MUST submit a plan-specific document (such as a summary plan description, summary material modification, benefits summary, schedule of benefits, etc.) that affirms coverage of transition-related care. A clinical policy alone cannot be accepted for credit.

To receive credit in the CEI, a company must:

• Upload a copy of the applicable medical policy for transition-related services, treatment of gender dysphoria, or similar title.

• A clinical policy bulletin (or medical policy) is a document that explains an insurer's determination of whether a service is medically necessary, how coverage is administered by the insurer and under what circumstances. Clinical policy bulletins are not benefit contracts and do not constitute coverage on their own.
• Learn more about these documents here

Examples:

• Transgender and Gender Diverse Services - BCBS Massachusetts
• Gender Reassignment Surgery with Related Services - BCBS Illinois

Note: For the purposes of the CEI, a clinical policy alone (without a summary plan description or the like) is insufficient for credit. The reason for this is: clinical policies (aka medical policies) are an explanation of how a benefit is medically administered and managed and they do not constitute proof of coverage. This is clearly stated in most clinical policies documents.

To receive credit in the CEI, a company must:

• Have at least one plan that covers the following benefits for the treatment of gender dysphoria:
  • Mental health counseling
  • Hormone replacement therapy
  • Routine doctor’s visits and lab testing
  • Surgical procedures
  • Paid short-term leave (whether employer provided or employer purchased)

More Information:

• Baseline surgical procedure coverage must include reconstructive chest/breast and genital surgeries for transmasculine and transfeminine individuals.

To receive credit in the CEI, a company must:

• Have eliminated all separate monetary caps of transition-related coverage. Plans with monetary caps (regardless of amount) cannot be accepted for credit.

More information:

• Treatment is Not Expensive: Includes available cost and utilization data demonstrating that costs of treatments are inexpensive and utilization of benefits is low.

To receive credit in the CEI, a company must:

• Have eliminated all blanket exclusions for transition-related care across all health care plans
• Have the appropriate executive-level person confirm that all benefit plans have been reviewed and blanket exclusions on transition-related care have been removed by affirming the following statement with a digital signature:
  • I can affirm that all benefit plans have been examined, and no blanket exclusions on transition-related care are included in any of the company's benefit plans.

More information:

Most U.S. health insurance policies have exclusions listed on transition-related care – right alongside those for cosmetic or experimental care – even though treatment of gender identity disorder is neither cosmetic nor experimental.

Historically, the vast majority of commercial health insurance plans in the United States excluded all or most coverage for treatment related to gender transition. This “transgender exclusion” denies coverage for treatments such as psychological counseling for initial diagnosis and ongoing transition assistance, hormone replacement therapy, doctor’s office visits to monitor hormone replacement therapy and surgeries related to sex reassignment. Sometimes the exclusion’s language is sufficiently broad enough to deny coverage to a transgender person for treatments unrelated to transitioning, such as for a transgender man with a broken arm. These exclusions are based in part on bias against transgender and non-binary people, and also in part on the erroneous belief that the cost of transition-related or gender-affirming care is high, which is not true. Furthermore, the healthcare industry is heavily reliant on a binary definition of gender, such that a transgender woman may be denied coverage for a prostate screening or a transgender man for a pap smear. Exclusions are generally found in a benefits summary plan description, which is available to all employees and applicants.

The good news is that many large corporations have removed most of the transgender exclusions from their health insurance policies and have affirmed benefits covering their transgender or transitioning employees to provide a base level of coverage for medical care, including mental health counseling, hormone therapy, puberty blockers for youth, medical visits and surgical procedures, and have provided short-term leave for treatments related to gender transition. Companies have had great success in removing discriminatory exclusions when they negotiate with their carriers and especially when they are able to provide a high level of information to the carrier in the process.

Source: Gender Diversity in the Workplace: A Transgender & Non-binary Toolkit for Employers

A complete list of exclusions will be found in the insurance contract, and partial lists are usually found in summary plan documents.

For the CEI 2023/2024 survey, HRC originally put forth an evolution in scoring for transgender-inclusive benefits that added a requirement to provide additional baseline benefits to employees. After consulting with key stakeholders and considering the constraints on benefit package/contract updates, this criterion was not implemented for the CEI 2023/2024.

For the 2025 CEI, we have decided to provide CEI participants with additional time to update benefits packages for their employees. The 2025 CEI Survey will continue to measure the transgender-inclusive healthcare benefits criterion utilized for the 2023/2024 CEI and outlined below.

The revised scoring criteria for transgender inclusive healthcare benefits will be implemented in the 2026 CEI survey cycle. This decision was not made lightly; healthcare contract timing concerns, recently revised WPATH (World Professional Association for Transgender Health) SOC 8 Guidelines, and increasingly complex legal considerations related to access to care resulting from state-based gender affirming care bans all contributed to the need for additional time to meet our organization’s and our participants’ goals.

As always, our goal is to ensure the CEI criteria aligns with leading practices in LGBTQ+ workplace benefits, policies, and practices. As the criteria evolve HRC commits to providing ample notice, information, and resources to effectuate successful changes.

2026 Transgender Inclusive Healthcare Benefits Criterion

To secure full credit for benefits criteria, benefit must be explicitly affirmed in contract documentation and available to all benefits-eligible U.S. employees. When more than one health insurance plan is available, at least one inclusive plan must be available. Broad exclusions must be removed from all plans.

Equal health coverage for transgender individuals without exclusion for medically necessary care (15 points possible).

Baseline coverage MUST include each of the following):

• Mental health benefits
• Pharmaceutical coverage (e.g. hormone replacement therapies, including puberty blockers for youth)
• Coverage for medical visits or laboratory services
• Coverage for reconstructive surgical procedures related to gender affirmation (including reconstructive chest, breast, and genital procedures)
• Short-term medical leave

Additionally, at least 5 of the following essential services and treatments must be available

(10 points possible):

• Hair removal, such as electrolysis, laser treatment, etc. (not as a part of reconstructive surgery)
• Hair removal required for reconstructive surgery
• Tracheal shave/reduction
• Facial surgeries
• Voice modification surgery
• Voice modification therapy
• Lipoplasty/filling for body masculinization or feminization
• Travel and lodging expenses