Submitting a public comment? Why??
I just did an advocacy action I've never done before. Hooray!
When I heard about the Drug Enforcement Administration (DEA) limiting access to lifesaving hormone therapy for transgender people, I was really worried. This Instagram post I found said it would explain what we could do to stop it, so of course I was intrigued.
I assumed the action alert would be, as usual, a phone call. They'd tell which office is in charge, and maybe there would be a script for what we should say to them.
I've made phone calls to federal and state offices before. I've written letters to Congress.
... But what the heck is a public comment, and why would you want me to do that?
I'm writing this blog post to 1) encourage people to take the action this week, and 2) walk through the process of doing an advocacy action outside my comfort zone. If you're reading this after March 31, 2023, and the opportunity to participate in this specific action has passed, do not fear! Do not cry into your soup!
You can still read this, and hopefully it will help you feel prepared to demystify some other advocacy action for yourself in the future. Maybe there's an occasion coming up to submit public comments again on something else!
Why are we doing this? (What's going on?)
Honestly, I think Them did a much better job summarizing the issue than I could, so I'm just going to link the article here: https://www.them.us/story/dea-telehealth-rules-testosterone
Basically, the Drug Enforcement Administration (DEA) is deciding on a proposed change to the current rules about telehealth. And it has a disproportionate impact on transgender patients, (especially those who are disabled, live in a rural area, or at risk for other reasons, as you'll see).
Are you familiar with telehealth?
Personally, I use telehealth for my anxiety disorder-- I actually had a virtual psychiatry appointment just this morning! (Shoutout to my psychiatrist, she's truly the best.) When I meet with my psychiatrist online, she checks in with me about my mental health and we discuss whether any changes need to be made to my medication, or if she should just continue refilling my normal prescription for anxiety meds. Then, a few days later, I stroll down the street to CVS to pick up my pills. It's a nice, convenient process that gets me the medication I need without going out of my way to visit a doctor's office (as a college student without a car, that would be a pain.)
So, that's one example. But sometimes telehealth isn't just about anxiety meds. There's a list of "controlled substances" that the DEA is concerned about right now, and that's where the rule change comes in.
They want to make it so that you can't get prescribed certain controlled substances unless you visit in person. And since testosterone happens to be on that list of controlled substances, that's a problem for transgender patients who use testosterone for hormone therapy to treat their gender dysphoria.
(Estrogen, another hormone that many transgender people use, is not affected by this rule change. Apparently it's classified under a different list.)
Requiring in-person visits will make it harder for many people to access the testosterone they need. What if you live far away from your healthcare provider? Have a disability that hinders travel? Can't take time off work without consequences? What if taking a significant part of your day to travel for hormone therapy puts you at risk because of stigma and backlash?
... You see the issues with this.
I was worried about the rule change, as I know many people who have benefited from taking testosterone, and I wanted to do something. Apparently, the *thing to do* this week is leave a public comment with the DEA. I wasn't familiar with it, but here's the process I discovered:
How to leave a public comment about a DEA rule change
1. First, you follow the link provided by whomever recommended the action to you. In this case, it's bit.ly/protecttelehealth.
2. Write a message in the provided text box. I provided mine as an example, later in this post. My comment was 204 words long, but I'm assuming significantly shorter or longer pieces are fine as well.
Are you stuck, wondering what to say?
- You can include a few sentences about what it means to you personally, or your community.
- You can mention the different groups of people who will be disproportionately affected and harmed by the rule change. There might be talking points you've seen on social media that resonate with your personal values, and you can talk about that!
- You can bring up current events. Has this issue been in the news a lot? Is that context important for how the rules will end up being enforced?
- INCLUDE A CALL TO ACTION. The above points are all optional suggestions, but the one thing you really must remember is to get to the point. Do you approve or reject the policy? What do you want the government to do, or change?
I noticed that when I selected "I am an individual," the form loaded additional questions asking for more information. First and last name were required fields, and then the following were optional: City, State, ZIP code, Country, and Phone Number. It seems that any information you fill out here might become publicly viewable information on the internet once your comment gets approved and posted, so make an informed decision. You do not have to give them your location and phone number if you don't want to.
4. Submit your comment. (It won't be approved right away because there's a review process I honestly don't know much about, but you can at least make sure the request went through.) My comment was approved within 12 hours of when I submitted it. For the telehealth testosterone action, the deadline for public comments is March 31, 2023, at 11:59 pm EST.
5. Multiply your impact! Tell a friend about the action you took, and ask them to do it, too. I may not be an expert in public comments, but I know advocacy is more powerful in greater numbers. There's a reason activists try to share these articles, Instagram posts, and action alerts as widely as possible.
As an example, here's the comment I left. (As I've mentioned already, I've never done this before. I have no idea if I did it "right" so please don't assume yours has to look anything like mine.)
"I am strongly opposed to this proposal, as it is currently stated. The consequential threat to gender affirming care would be very harmful.
"A special exemption should be created for testosterone and androgen treatment in cases of gender dysphoria and gender incongruence. Furthermore, testosterone ought to be removed from the list of controlled substances."These changes would then protect telehealth prescriptions that are crucial to transgender health and well-being for many members of the LGBTQ+ community.
"This proposal, as currently written, would require in-person visits for an individual to fully access hormone therapy for gender dysphoria, and those visits can be difficult to accomplish for people living outside major cities, some disabled people, and anyone who struggles to take time off work to visit a doctor's office that is far away. Transgender patients who live rurally, have disabilities hindering travel, or who fear outing and harassment need access to lifesaving telemedicine.
"Private and affirming care for transgender patients is under threat from so many different fronts. It is imperative that the DEA maintains telehealth as an option for this community.
"Once again, I urge this policy to be revised. Remove testosterone from the list of controlled substances, and create a special exemption for hormone treatments for gender dysphoria."
Ta-da.
You definitely noticed this already, but since I don't know what comments usually look like for DEA proposals, I stuck with formal and stuffy language. I doubt that's a requirement-- I was just in that sort of mood, I guess, and was nervous about being taken seriously on a platform I've never interacted with before.
Again, I'm not saying that's a model or standard in anyway. I could not be less of an expert in bombarding the DEA with public comments. Hopefully, by sharing my attempt, it encourages other newbies to give it a try, too!
As long as you make a sincere attempt to protect transgender healthcare, I highly doubt that you could somehow do a public comment "wrong."
Why are we doing this? (part 2: electric boogaloo) (Why use public comments, rather than another advocacy tactic?)
Since I'm not familiar with this type of advocacy action, I don't have data or anecdotal evidence speaking to its impact. I don't know how much influence public comments actually hold, or how many are typically posted for proposed DEA rule changes.
But I still found it worth doing, and worth writing about, as an example of concrete advocacy for transgender healthcare.
This is something transgender people can do for ourselves and each other that isn't a huge time commitment. This is an act of allyship cisgender people can engage in beyond "be nice about pronouns." (Top of mind for me, because I just completed a required diversity module for my college, and literally the only thing they talked about for gender diversity was pronouns. Respecting pronouns is definitely important, of course, but transgender people are under attack from all sides and we need much more than pronouns right now.)
For people reading worrying news about anti-trans bills, drag bans, and hate crimes across the country, this is something concrete you can do that will be seen by government officials and by trans activists who could be encouraged by support from the general public.
What other options for action-taking are out there?
There are marches happening all over the country-- I have plans to show up at in person actions in Baltimore and DC with my protest buddies this weekend. (Be safe. Wear a mask.)
There are mutual aid networks where you can send money to support transgender folks in your community, helping with things that are directly related to gender-affirming care like surgery costs, or just general survival funds. If you're not connected with local mutual aid already and you have some extra funds to help someone, Trans Lifeline has this list you can use as a starting point: https://translifeline.org/resource/mutual-aid-funds-public-assistance/.
There are organizations you can donate to or volunteer for, and even just follow them on social media so you know when the next action alerts go out. I rely a lot on PROMO in Missouri and FreeState Justice in Maryland to keep up with legislation and advocacy in my two home states. Local resources like SQSH (they provide a support helpline and awesome community spaces in St. Louis, Missouri) are also fantastic-- say, if submitting to an LGBTQ+ arts and writing anthology is more your speed than public speaking at a protest? There is room for everyone's strengths and passions in this movement!
And then, of course, there's the calling-and-writing brand advocacy actions. Phone calls to legislators. Public comments for the DEA. If you choose to engage in some of these actions, I commend you. I also know it can feel pointless sometimes because of the enormity of what we're up against.
I'm gonna be real with you-- your small paragraph probably won't change a stubborn bigot's mind. But you know what it will do? You'll get practice writing about trans health issues. (Skill building! We need it, to build strong movements.) You'll get the satisfaction of doing something with small that still definitely has a nonzero impact. You'll join a flood of joyous, adamant queer liberation advocacy and who knows, we might even win this one.
There's probably someone working at the DEA who is concerned about transgender people and what this policy means for them, and seeing public comments in support could be just the thing they need to get spurred into action.
What does it take to make a difference? I'm not asking you to fight the entire U.S. government. These are just a few suggestions for what you can include in your day.
When you have schoolwork and laundry to do, meals to eat, and immense stress to manage, it is enough to sincerely care about people and do something in your power to help.
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