Utah lawmakers will soon decide whether to keep laws in place protecting kids from transgender procedures. Their decision will be based in a large part on a report the Utah legislature commissioned — a report one watchdog says is “terribly flawed.”
Do No Harm on Tuesday released a memo highlighting the problems with a report commissioned by the Utah legislature on transgender procedures on kids. The memo, first shared with The Daily Wire, says that the report significantly misrepresents the scientific record and glosses over the danger of transgender procedures.
“Its 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,” Do No Harm medical director Kurt Micelli and gender ideology program director Michelle Havrilla write.
The May 2025 report, titled “Gender-Affirming Medical Treatments for Pediatric Patients with Gender Dysphoria,” was conducted by the Drug Regimen Review Center at the University of Utah and led by Dr. Joanne LaFleur. It was commissioned after Utah Republicans passed legislation in 2023 to shield kids from transgender procedures by putting a moratorium on puberty blockers and cross-sex hormones.
The purpose of the report is to guide the Utah Department of Health’s recommendations to the legislature about whether to keep the ban on hormonal procedures in place. After an in depth review of the 1,000-page report, Do No Harm said that the legislature should ignore the Utah report, and instead rely on a Department of Health Health and Human Services review that found putting kids on puberty blockers or cross-sex hormones damaged their development and comes with serious health risks.
“The Utah Report asserts that puberty blockers and cross-sex hormones are safe and effective amid a sea of weak evidence, data extraction by a single reviewer rather than at least two, and conclusions based primarily on narrative summaries rather than quantitative synthesis – all despite reaching conflicting findings from well-established systematic reviews available prior to the Utah Report’s submission,” Do No Harm writes in its memo.
This portrayal comes from a reliance on anecdotal stories and studies, and not a systematic review of all relevant studies. Micelli told The Daily Wire that the Utah Report was “terribly flawed” and “anything but” a systematic review, and did not conduct critical evaluation of the studies cited.
“Unlike true systematic reviews, it does not assess the reliability of studies and whether the research can provide guidance for weighing the risks and benefits of medical intervention for children with gender dysphoria,” the memo said.
Micelli and Havrilla write that the Utah report relied on observational studies as opposed to randomized control studies. The authors also pointed more to quantity over quality, they said.
At one point, the Utah authors wrote that “the amount of evidence available for treating pediatric [gender dysphoria] patients with [gender-affirming hormonal therapy] far exceeds the quantity that supported the use of [spinal muscular atrophy] gene therapy upon FDA approval.”
The gene therapy approval was based on objective testing while the transgender studies were based on subjective methods, Do No Harm warned.
The Utah authors also accepted the guidance of radical groups like the World Professional Association for Transgender Health (WPATH) and the Endocrine Society. Both these groups downplay the risks of transgender procedures on kids and endorse things like cross-sex hormones and puberty blockers.
Micelli said that the Utah report treats the WPATH guidelines “as gospel” and offer “no critical evaluation.”
The Utah report takes “these guidelines at face value purely because they come from ‘organizations that are widely regarded as authorities in their given specialty’ and state ‘a risk-of-bias assessment was not conducted on guidelines as part of the current work because [the authors] restricted inclusion to recognized medical authorities who published evidence-based guidelines,'” the memo noted.
Both WPATH and the Endocrine Society make the dubious suggestion that it’s possible to reverse the effects of puberty blockers. This contradicts evidence that puberty blockers stunt bone development and have unknown neurological impacts.
Other well-documented problems with transgender procedures on kids are also downplayed, Do No Harm notes. For example, the risk of sexual dysfunction from cross-sex hormones is not mentioned and potential dangers to infertility are not included as an outcome of focus.
“They conclude that gender-affirming hormone therapy (GAHT) is effective in improving mental health and psychosocial outcomes, whereas concerns related to bone health, cardiovascular risk, and cancer are ‘minimal and manageable.’ The Utah Report neglects significant adverse effects that are associated with GAHT, including the life-altering effects of infertility/sterility and sexual dysfunction.”
While the recommendations added on to report as claim that no position is being taken on whether to continue the moratorium on trans procedures, Micelli told The Daily Wire that is a contradictory claim. The recommendations are all contingent on the moratorium being lifted, Micelli said. These included things like setting up a board to oversee the moratorium, creating specific standards of care, and limiting those who prescribe transgender procedures to “demonstrated experts.”
Do No Harm also flagged multiple doctors recommended by the Utah report’s amendments as advisors to lawmakers for potential conflicts of interest. This included Nikki Mihalopoulos and Brooks Keeshin.
Mihapopoulos authored a 2021 article discussing how “pediatric health care providers can play a critical role in building solutions in policy and advocacy…to improve the health of transgender/gender diverse youth. Many government entities, especially at the state and local level, actively resist efforts promoting equal rights.”
Keeshin has written a “Clinical Perspective” highlighting Utah’s “potential pathway forward” for “open access to [gender-affirming] care” for adolescents and said that the protections created a “significant challenge to adolescents who would benefit from gender-affirming care as well as their healthcare providers.”
