A medical watchdog group has sharply criticized a University of Utah report on gender-affirming medical treatments for minors as methodologically unsound and misleading. The report, commissioned to guide state decisions on whether to maintain a moratorium on certain hormonal treatments, is accused of overstating benefits, downplaying risks, and relying too heavily on guidelines from advocacy-aligned medical organizations.
Utah lawmakers are preparing to decide whether to maintain a 2023 moratorium on puberty blockers and cross-sex hormones for most minors, a measure passed by Republican legislators as part of an effort they said was meant to protect children from what they describe as transgender medical interventions. Their decision is expected to rely in large part on a lengthy report the legislature commissioned.
According to a memo released Tuesday by the watchdog group Do No Harm and first reported by The Daily Wire, the Utah Legislature requested a review of the evidence on hormonal treatments for minors following the 2023 law. The resulting May 2025 report, titled “Gender-Affirming Medical Treatments for Pediatric Patients with Gender Dysphoria,” was produced by the Drug Regimen Review Center at the University of Utah and led by pharmacist and researcher Dr. Joanne LaFleur. The roughly 1,000-page report is intended to guide the Utah Department of Health and Human Services (DHHS) in making recommendations to lawmakers on whether to continue or modify the moratorium.
In its memo, Do No Harm contends that the Utah report significantly misrepresents the strength and balance of the scientific record on gender-affirming hormonal interventions. Medical director Dr. Kurt Micelli and gender ideology program director Michelle Havrilla wrote that the report’s “shortcomings include failure to adhere to the fundamental standards of a systematic review, prioritizing the quantity of evidence over its quality, uncritically relying on guidelines from purported experts, overlooking significant life-altering adverse effects, and consulting advisors, some of whom support ‘gender-affirming care’ for minors,” according to language quoted by The Daily Wire.
The memo argues that the Utah report asserts that puberty blockers and cross-sex hormones are safe and effective despite what Do No Harm characterizes as weak underlying evidence, reliance on a single reviewer for data extraction, and conclusions drawn primarily from narrative summaries rather than quantitative synthesis. The watchdog group says those methods conflict with more stringent approaches used in prior systematic reviews and that the Utah document leans heavily on observational studies and anecdotal evidence rather than randomized controlled trials.
Micelli told The Daily Wire that, in his view, the Utah report is “terribly flawed” and “anything but” a true systematic review, arguing that it does not adequately assess the reliability and limitations of the studies it cites.
Do No Harm also criticizes the Utah report for its use of clinical guidelines from the World Professional Association for Transgender Health (WPATH) and the Endocrine Society. The memo states that the authors of the Utah report treat these guidelines “as gospel” and notes that the report says it did not perform a risk-of-bias assessment of such guidelines because they were issued by “recognized medical authorities who published evidence-based guidelines,” according to excerpts reported by The Daily Wire.
The watchdog organization contends that guidelines from WPATH and the Endocrine Society endorse puberty blockers and cross-sex hormones for some minors while, in its view, downplaying risks. Do No Harm argues that these guidelines suggest that effects of puberty blockers can be reversed, a claim the group says is inconsistent with evidence that such medications can impair bone mineral density and may have neurological effects that are not yet fully understood. The memo further faults the Utah report for not listing infertility and sexual dysfunction as key adverse outcomes of cross-sex hormones, while concluding that concerns about bone health, cardiovascular risk and cancer are “minimal and manageable.”
The watchdog group urges lawmakers to give little weight to the Utah report and instead look to other national reviews, including an analysis by the U.S. Department of Health and Human Services that Do No Harm says highlights developmental harms and serious health risks from puberty blockers and cross-sex hormones. (DHHS maintains official guidance supporting gender-affirming care; Do No Harm, a group critical of such care, disputes the robustness and interpretation of the federal evidence base.)
Do No Harm also points to what it describes as potential conflicts of interest among some of the advisors suggested in the Utah report. The memo singles out pediatrician Dr. Nikki Mihalopoulos, noting that she co-authored a 2021 article that called for policy changes to improve health outcomes for transgender youth amid resistance from some government entities, and child abuse pediatrician and psychiatrist Dr. Brooks Keeshin, who, according to the memo, described Utah’s moratorium as a “significant challenge” to access to gender-affirming care. The memo argues such positions may signal a predisposition in favor of these interventions.
While the Utah report’s recommendations state that they do not take a position on whether the moratorium should continue, Micelli told The Daily Wire that he believes the recommendations effectively assume the moratorium will be lifted. He points to proposed steps such as creating an oversight board, setting specific standards for gender-related medical care, and limiting prescribing authority for these interventions to clinicians deemed “demonstrated experts” as measures that would only be relevant if new treatments were permitted to proceed.
The University of Utah team that produced the report and the Utah Department of Health and Human Services did not respond in the Daily Wire article to the criticisms raised by Do No Harm. Major U.S. medical organizations, including the American Academy of Pediatrics and the Endocrine Society, continue to support access to gender-affirming care for minors under clinical guidelines, while some international health systems and independent reviewers have moved toward tighter restrictions or more cautious approaches. Policymakers in Utah are expected to weigh these competing interpretations as they decide whether to maintain, modify or lift the state’s current moratorium on hormonal treatments for minors.