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.

2025 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.

Required benefits include:

• Mental health benefits
• Pharmaceutical coverage (hormone replacement therapies)
• Coverage for medical visits or lab services
• Coverage for reconstructive surgical procedures (must include chest, breast, and genital procedures)
• Short-term medical leave

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 reassignment (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 feminization surgeries
• Voice modification surgery
• Voice modification therapy
• Lipoplasty/filling for body masculinization or feminization
• Travel and lodging expenses