668 - Analysis of Public Comments as a Tool to Support Pediatrician Advocacy

Publication Number: 4654.668

Morissa Ladinsky, Stanford University School of Medicine and Child Health, Emerald Hills, CA, United States; Colt St. Amand, Riverside Family Medicine, Oneonta, NY, United States; Drew B. A.. Clark, The University of British Columbia, Vancouver, BC, Canada; Russell B. Toomey, University of Arizona, Tucson, AZ, United States

Background: Pediatricians, as advocates for and experts in child health, leverage expertise to advance the health of youth. Advocacy is not only an element of professionalism, but a moral imperative. Accelerated by the rapid spread of health misinformation, public trust in science and medicine are now diminishing. One field targeted by exceptional health misinformation is pediatric gender-affirming care (GAC). While evidence based standard of care medicine has ensured trans-youth health for decades, it has recently been placed under a high level of scrutiny.

For pediatricians to remain critical and trusted voices, innovative tools are necessary to support advocacy, such as analysis of public comments. Federal law mandates public response to a proposed rule or regulation to help agencies incorporate public expertise into federal regulations. The Federal Trade Commission (FTC) is one agency that employs public comment as part of its role in protecting the public from fraudulent business practices, deception, and unwieldy mergers

Objective: The objective of this project was to analyze public comments. Here we describe real time pediatrician analysis of public comments in response to the FTC’s 60-day “Request for Public Comment Regarding Gender-Affirming Care for Minors to better understand how consumers may have been exposed to false or unsupported claims”, issued on July 28, 2025.

Design/Methods: Public comments submitted to this call were downloaded from the FTC website and coded using qualitative directed content analysis. Frequency counts were employed to describe the characteristics of respondents and the content of the submissions.

Results: Over 8,000 publicly viewable submissions were made to the FTC. Preliminary analysis shows 86% of these comments supported minor access to GAC while 14% did not. Commenters were overwhelmingly adults. Key initial themes from responses in support of GAC for minors included: life-saving; improves health; patient autonomy/rights; not a government decision; evidence supports GAC. Comments opposing GAC for minors invoked language about stopping mutilation of children and protecting innocent children. This presentation will include detailed analysis of respondent types and response themes, inclusive of exemplary quotes

Conclusion(s): Analysis of public comments by medical providers using qualitative methods in real time is a novel way to support advocacy through identifying health misinformation while upholding science and evidence-based practice.