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LOVEboldly's Comments on Draft Rules 3701-3-17; 3701-59-06; 3701-83-61; 5122-26-19; and 5122-14-12

Dr. Ben Huelskamp on behalf of the LOVEboldly Board of Directors and Community

Jan 19, 2024

January 19, 2024

Bruce Vanderhoff LeeAnne Cornyn

Director Director

Ohio Department of Health Ohio Department of Mental Health and Addiction Services

Submitted electronically to and

Director Vanderhoff and Director Cornyn:

Thank you for the opportunity to submit comments regarding draft rules: 3701-3-17; 3701-59-06; 3701-83-61; 5122-26-19; and 5122-14-12. LOVEboldly, an Ohio faith-based nonprofit working to create more spaces where LGBTQIA+ people can flourish in Christianity, is deeply concern about the obviously partisan and ideological nature of the draft rules and their contradiction of nationally accepted standards of care for Transgender people. As Christians, we also worry about how these rules will lead medical providers to work against their consciences and faiths which urge them to offer gender-affirming care to all patients and to do no harm.

These rules represent a departure from rigorous medical science and an entrance into the world of misinformation and conjecture. Evidence-based and well researched protocols and standards of care already exist for the treatment of gender dysphoria and the care of transgender individuals seeking any level of medical care including the World Professional Association for Transgender Health’s Standards of Care (8th edition) and the Endocrine Society’s Clinical Practice Guideline. These guidelines are recognized by every major medical association in the United States.

In fact, the proposed rules embrace protocols often used with pediatric patients and apply those protocols to adults. Anyone who has seen a season of Grey’s Anatomy knows that the physiology of children is different than that of adults and anyone who has had children or worked in education knows that the psychological needs of children are also different than those of adults.

We could continue to repeat scientific and policy arguments to you, but we know that our partners throughout Ohio’s LGBTQIA+ community have and will continue representing those arguments. We are not an organization of scientists, doctors, or mental health providers, though we have those people in our community. We are faithful, progressive, and Queer and allied Christians. Our faith compels us to enter the public square and represent the radically inclusive message of Jesus. We believe that God creates transgender people and blesses their gender transitions just as God creates and blesses all other LGBTQIA+ people.

Based on that understanding, we consider these rules to be acts of sin and we condemn them in the strongest of terms. We urge you to reject the rules in their entirety and to act in the best interests of all Ohioans, particularly Transgender Ohioans, by relying on the standards of care which already exist.


Dr. Ben Huelskamp

On behalf of the LOVEboldly Board of Directors and Community

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