The Center for HIV Law and Policy (CHLP) submitted these comments to NYC Administration for Children’s Services on its Safe & Respected: Policy, Best Practices, & Guidance for Serving Transgender and Gender Non-Conforming Children and Youth in the Child Welfare and Juvenile Justice System draft policy. The comments focus on the draft policy’s provisions related to sexual health care for transgender and gender nonconforming (TGNC) young people, and highlight various ambiguities and omissions that may negatively affect these services.
CHLP points out that the policy lacks specificity regarding timelines for the request, administrative review, approval or denial, and provision of all medical transition services requested by TGNC youth. There is similar ambiguity regarding what should be done in the event that private or public funding is unavailable for these services. The policy also does not address sexual health care services or sexual health capacity-building resources for TGNC youth that are unrelated to medical transition care, despite the fact that TGNC youth are disproportionately affected by sexually transmitted infections, including HIV, and sexual violence.