Where We Stand

Equitas Health advocates for the rights and healthcare access of LGBTQ+ individuals and other at-risk communities. Here are some of our advocacy efforts in 2022:

• Supporting House Bill 135
• Promoting the Ohio Fairness Act
• Advocating for transgender inclusion
• Protecting gender-affirming care, championing student rights
• Safeguarding Section 1557 of the ACA
• Enhancing Title IX protections
• Ensuring equitable ARPA fund distribution
• Maintaining social work standards
• Expanding access to the Mpox vaccine.

Equitas Health advocates for the rights and healthcare access of LGBTQ+ individuals and other at-risk communities. Here are some of our advocacy efforts in 2023:

• Attending over 90 community events and protests
• Serving over 300 clients at legal clinics for name and gender marker changes
• Joining 12 national coalitions for various policy changes
• Appearing in 14 news articles on key issues
• Publishing 8 blog posts on public policy and advocacy
• Filing 27 pieces of public comment and testimony
• Logging over 31,000 views on social media updates

On Mar. 18 and Mar. 21, the Ohio Department of Mental Health & Addiction Services and the Ohio Department of Health will host public hearings for the proposed, revised administrative rules. Equitas Health submitted public comments against each proposal.

Read Full Comments – Revised MHAS proposal (PDF)

Read Full Comments – Revised ODH proposal (PDF)

On Feb. 7, 2024, after record-breaking numbers of public comments, the Ohio Department of Mental Health & Addiction Services (MHAS) proposed revised administrative rules. Restrictions to adult care were removed, but adult reporting requirements remained, and the other portions of the proposal still targets transgender, non-binary, gender expansive, and intersex youth. The MHAS reopened a shortened window for public comments, and Equitas Health submitted public comments against the proposal.

Read Full Comments – Rule 5122-14-12.1 & Rule 5122-26-19 (PDF)

On Jan. 5, 2024, Gov. DeWine proposed administrative rule changes that would all but ban gender affirming care for Ohioans of any age. The Ohio Department of Mental Health & Addiction Services (MHAS) and the Ohio Department of Health (ODH) outlined DeWine’s proposed administrative rule changes in separate proposals. The MHAS proposal included changes to Rule 5122-14-12 and the addition of Rule 5122-26-19; the ODH proposal included changes to multiple sets of existing rules.

Read Full Comments – Rule 5122-14-12 (PDF)

Read Full Comments – Rule 5122-26-19 (PDF)

Read Full Comments – Rules 3701-3-17; 3701-59-07; and 3701-83-61 (PDF)

On Apr. 15, 2024, JCARR reviewed rules from both MHAS and ODH proposals. Two anti-trans rules were validated and can be implemented by ODH as early as Apr. 25. One rule was marked as TBR (to be refiled) for potential consideration by JCARR at a future date.

Read Full Comments – ODH Rules for Gender Affirming Care

Read Full Comments – MHAS Rules for Gender Affirming Care

Read Verbal Testimony 

We applaud the Centers for Disease Control and Prevention’s (CDC) release of evidence-based guidelines linked to the use of doxycycline post-exposure prophylaxis (DoxyPEP). DoxyPEP has been proven to lower the risk of bacterial sexually transmitted infections (STIs) by up to 70%. In response to the CDC’s request for comment on the proposed guidelines, we recommend the CDC:

• Issue a non-discriminatory & evidence-based Final Guidance about DoxyPEP
• Actively promote DoxyPEP’s use for STI prevention
• Consult with LGBTQ+ and HIV/AIDS-focused community health centers in any future changes to the proposed rules

Ryan White Clinics for 340B Access (RWC-340B) express gratitude to Senators Thune, Stabenow, Capito, Baldwin, Moran, and Cardin for proposing a legislative framework to protect and improve the federal 340B drug pricing program. RWC-340B, representing HIV/AIDS health care providers, has reviewed the draft “SUSTAIN 340B Act” and submitted detailed feedback. The clinics emphasize that the 340B program’s legislative intent should remain unchanged, avoiding restructuring into a patient drug assistance program, and urge Congress to protect safety net providers. Key recommendations include prohibiting restrictive access limits, stopping manufacturer control over contract pharmacies, and reducing unnecessary reporting burdens. Additionally, RWC-340B supports the PROTECT Act and clarifying HRSA’s authority to audit manufacturers.

Read (PDF)

Equitas Health comments regarding the Bipartisan 340B Senate Working Group’s SUSTAIN 340B Act. Equitas Health, a leading LGBTQ+ and HIV/AIDS healthcare provider, underscores the importance of maintaining the integrity and accessibility of the 340B Drug Pricing Program. We advocate for the unrestricted use of contract pharmacies, highlight the significance of setting a clear patient definition, and recommend exempting Ryan White clinics from specific provisions. Additionally, we emphasize the need for transparency without imposing undue burdens on federal grantees and support the establishment of a 340B Clearinghouse to prevent duplicate discounts. Equitas Health also urges the prohibition of discriminatory practices by pharmacy benefit managers to protect vulnerable patients.

Read (PDF)

The National Association of Community Health Centers (NACHC) and nearly 400 undersigned organizations, express gratitude to the Senators for considering our feedback on the SUSTAIN 340B Act. NACHC, representing Federally Qualified Health Centers (CHCs), underscores the importance of the 340B program, which has enabled CHCs to provide affordable medications to underserved patients. This program has been vital in supporting health centers’ comprehensive services, including dental, behavioral, and primary care. We emphasize the need for legislative reforms to ensure the program’s sustainability, addressing issues like contract pharmacy restrictions and actions by Pharmacy Benefit Managers that threaten CHCs’ financial stability. Additionally, we actively supported coalition responses from Ryan White Clinics for 340B Access (RWC-340B) and the National Association of Community Health Centers (NACHC).

Read (PDF)

Additional Insights on 340B Program Revisions
We’ve been working to ensure the stability of the 340B Drug Pricing Program while maintaining patient access. I’ve included recommendations to update contract pharmacy language, redefine patient terms, and ensure fair auditing processes. These changes reflect our commitment to advancing healthcare for all, especially those in the LGBTQ+ and HIV communities.
Read (PDF)

Representing one of the largest LGBTQ+ and HIV/AIDS healthcare organizations in the country, Equitas Health advocates for the rights of transgender, non-binary, gender expansive, and intersex students to participate in school sports without discrimination. The letter urges the DOE to prohibit categorical bans on these students and to implement stronger safeguards against discriminatory loopholes. Equitas Health emphasizes the need for fair and inclusive policies that support the health and well-being of all student-athletes.
Read Full Comments – Sports Ban Testimony (PDF)

Survivor advocate, gender justice, and civil rights organizations express their support for the Department of Education’s proposed changes to Title IX regulations. While recognizing progress made over 50 years, the letter highlights ongoing issues such as sex-based harassment, discrimination against LGBTQI+ students, and barriers faced by pregnant and parenting students. The organizations commend the Department’s efforts to undo previous harmful changes but urge for stronger protections against sex discrimination in education.
Read Full Comments – Comment with NWLC (PDF)

LGBTQ+ justice, civil rights, and education organizations, respond to the U.S. Department of Education’s proposed Title IX rule on nondiscrimination in school sports. We advocate for equal opportunities for transgender, nonbinary, and intersex students to participate in sports consistent with their gender identity. While supporting the proposed rule’s intent, we urge revisions to eliminate any loopholes that allow discrimination under the guise of fairness or safety, ensuring robust protections and full inclusion for all students.
Read Full Comments – NPRM Comments (PDF)

Dr. Rhea Debussy, Director of External Affairs for Equitas Health, provides testimony opposing the allocation of nearly $1 million for police surveillance technology in Dayton. Equitas Health, a major LGBTQ+ and HIV/AIDS healthcare organization, highlights concerns about the systemic overpolicing of marginalized communities, including communities of color and LGBTQ+ individuals. The testimony references historical misuse of surveillance against these groups and urges the City Commission to reject the proposal to ensure justice in public safety.
Read Full Comments – Police Surveillance (PDF)

Dr. Rhea Debussy provides follow-up testimony expressing disappointment over the Dayton City Commission’s approval of nearly $1 million for police surveillance technology. Citing concerns from community organizations, Dr. Debussy highlights the documented history of overpolicing marginalized communities, including people of color and LGBTQ+ individuals. The testimony urges the commission to reconsider future decisions, emphasizing the importance of community input and the potential for funds to support more beneficial regional projects.

Equitas Health, a leading LGBTQ+ and HIV/AIDS healthcare organization, comments on proposed Medicaid and CHIP Managed Care rule (CMS-2439-P). The organization supports efforts to enhance access to care and improve service quality but raises concerns about workforce shortages and credentialing delays. Equitas Health recommends modifications to credentialing processes, emphasizes the importance of telehealth services, and supports proposals for accurate provider directories and secret shopper surveys to ensure compliance and maintain network adequacy.

Equitas Health opposes HB 183, a proposed bathroom bill. Equitas Health, a major LGBTQ+ and HIV/AIDS healthcare organization, emphasizes the harmful impact of such legislation on transgender, non-binary, and gender expansive youth. The testimony highlights the unconstitutional nature of the bill, its negative mental health implications, and the misalignment with Ohio’s educational values. Dr. Rhea Debussy, Director of External Affairs, calls for rejection of HB 183 to ensure safe, affirming environments for all students.
Read Full Comments – HB 183 Bathroom Bill (PDF)

The AIDS Budget and Appropriations Coalition (ABAC), comprising 121 organizations, urges Congress to increase funding for domestic HIV/AIDS programs. Highlighting the need for sufficient resources to end the HIV epidemic, ABAC requests specific funding for the Ending the HIV Epidemic Initiative, the Ryan White HIV/AIDS Program, and other critical CDC programs. Emphasizing the effectiveness of current biomedical and behavioral tools, the coalition stresses the importance of equitable access to these resources to combat HIV, STIs, hepatitis, TB, and overdose syndemics affecting vulnerable communities nationwide.
Read Full Letter

Equitas Health, along with 178 other organizations, urges Congress to allocate $100 million for a national PrEP program within the CDC’s Ending the HIV Epidemic initiative. Despite existing disparities in PrEP access among different communities, expanding access is crucial for reducing new HIV infections and associated costs. The coalition emphasizes the importance of equitable access to PrEP medications and related services, recommending comprehensive support for awareness, medical services, and provider capacity expansion. This funding is vital to achieving the goal of ending the HIV epidemic in the U.S.

The DEA wants to require an in-person medical visit to get controlled substances like testosterone. While we understand the need for patients to have a relationship with their provider, we also know that telehealth options work! We want the DEA to recognize telehealth and to remove restrictions, specifically in the context of gender affirming care and intersex-related care.

Equitas Health strongly supports the proposed “Nondiscrimination in Health Programs and Activities” rule. This rule enacts Section 1557 of the Affordable Care Act. Section 1557 ensures access to healthcare and coverage for all. We push for its adoption with suggested changes, such as extending protections to non-health programs, ensuring consistent language regarding sex discrimination, and strengthening notice requirements.

Equitas Health opposes the proposed “Resolution to Support Parents, Schools, and Districts in Rejecting Harmful, Coercive, and Burdensome Gender Identity Policies.” Dr. Rhea Debussy, Director of External Affairs, highlights the detrimental impact of such policies on transgender, non-binary, and gender expansive youth. Data shows that supportive educational environments lead to better mental health and academic outcomes for these students. Equitas Health advocates for the protection and validation of LGBTQ+ students’ identities, aligning with best practices and the values of Ohioans.
Read Full Comments – Ohio State Board of Education Resolution on Transgender Students (PDF)

Equitas Health opposes the “Resolution to Support Parents, Schools, and Districts in Rejecting Harmful, Coercive, and Burdensome Gender Identity Policies.” Dr. Rhea Debussy, Director of External Affairs, emphasizes that this resolution undermines protections for transgender, non-binary, and gender expansive youth. Data from the CDC, GLSEN, and The Trevor Project show that supportive environments lead to better mental health and academic outcomes for these students. Equitas Health urges the Ohio State Board of Education to reject this harmful resolution and uphold inclusive educational policies.
Read Full Comments – December 2022 Testimony (PDF)

Equitas Health opposes the “Resolution to Support Parents, Schools, and Districts in Rejecting Harmful, Coercive, and Burdensome Gender Identity Policies.” Dr. Rhea Debussy highlights the resolution’s failure to support transgender, non-binary, and gender expansive youth. Citing data from the CDC, GLSEN, and The Trevor Project, she emphasizes the importance of affirming environments for better mental health and academic outcomes. Equitas Health urges the Ohio State Board of Education to reject this harmful resolution and align with inclusive policies that support all students.
Read Full Comments – November 2022 Testimony (PDF)

Equitas Health opposes the “Resolution to Support Parents, Schools, and Districts in Rejecting Harmful, Coercive, and Burdensome Gender Identity Policies.” Dr. Rhea Debussy highlights the resolution’s threat to protections for transgender, non-binary, and gender expansive youth. Despite data from the CDC, GLSEN, and The Trevor Project showing the importance of supportive environments for these students, the resolution defends harmful policies. Equitas Health urges the Ohio State Board of Education to reject this resolution and uphold inclusive policies for the well-being of all students.
Read Full Comments – October 2022 Testimony (PDF)

Medicare’s pending reclassification of an HIV prevention medication will hinder access to the drug for LGBTQ+ seniors and others who need it most. The Centers for Medicare & Medicaid Services (CMS) in 2023 announced a proposed National Coverage Determination (NCD) for pre-exposure prophylaxis (PrEP) for HIV prevention. In April 2024, CMS then indicated that PrEP coverage will soon move from Medicare Part D (drug coverage) to Medicare Part B (medical insurance). The Centers for Disease Control and Prevention (CDC) notes that “PrEP reduces the risk of getting HIV from sex by about 99% when taken as prescribed.”

Equitas Health, one of the largest providers of gender-affirming care in Ohio, strongly opposes efforts by the state Legislature and Gov. Mike DeWine to restrict patient access to gender-affirming care and place undue administrative burdens on providers.

In late January 2023, the Food and Drug Administration (FDA) proposed changes to their guidance on who can give blood. Historically, their rules have discriminated against members of the LGBTQ+ community. As promised, Equitas Health gave feedback to the FDA in a public comment.

HIV Prevention and treatment choices have improved dramatically in recent years. Meds – like pre-exposure prophylaxis (PrEP) and post-exposure prophylaxis (PEP) – are very good at stopping HIV. Ohioans can visit OHIV.org to learn more about PrEP and PEP. They can also get help finding doctors and nurses who prescribe PrEP and PEP and apply for programs that pay for PrEP.

In November, Equitas Health signed a letter with the Drug Policy Alliance in support of federal legislation that decriminalizes the possession of personal-use amounts of drugs. As the Community Relations Manager for Harm Reduction in the Department of External Affairs, I urged Equitas Health to join the more than 150 organizations in signing the letter.

My first time going to the Ohio State Board of Education in early October was nerve-wracking to say the least. Outside, there were supportive protesters. Inside, allies, trans-identified humans, and religious conservatives filled the lobby. I watched a large group pray for the defeat of the “trans agenda.”

In my role as Director of External Affairs at Equitas Health, a lot of transgender, non-binary, and gender expansive folks have been asking me about mpox (MPX). Many of my colleagues here and at other community organizations have noticed the same thing.

To help answer these common questions, I sat down with Teagan Vaughn, PharmD, RPh, AAHIVP (She/Her). Teagan is the Director of Gender Affirming Care and a clinical pharmacist at Equitas Health.

In August, the U.S. Department of Health and Human Services proposed a rule that would bar discrimination in federally funded healthcare settings on the basis of sex, including sexual orientation and gender identity. While Equitas Health applauds these added protections, we told the government that we think the rule should go even further.

Annually recognized in July to mark the passage of the Americans with Disabilities Act (ADA) on July 26, 1990, Disability Pride Month is a time to celebrate people with disabilities. It’s also a time to actively celebrate this community’s identities and cultures, while also recognizing the contributions that people with disabilities have made and continue to make to our society.

The mpox emergency is a threat to public health. In early August, Equitas Health joined over 150 LGBTQ+ organizations in a call for greater action from the government. Led by CenterLink, the organizations sent the CDC a letter on behalf of LGBTQ+ people across the country.

Early this summer, Equitas Health promised to review proposed changes to Title IX regulations. The 50-year-old law bans sex discrimination and sexual harassment in school programs that get federal aid.

A new rule was introduced by the Biden administration in June, and it’s working to renew and strengthen protections for LGBTQ+ students, women and girls of color, and pregnant and parenting students. These regulations will replace a Trump-era rule that reduced protections for students and made it harder for survivors of assault to file a report.