Health and civil rights enforcement action. Oregon Attorney General Dan Rayfield led a coalition of 19 states and the District of Columbia in filing a lawsuit against the U.S. Department of Health and Human Services (HHS). The suit challenges a December 18, 2025 HHS 'declaration' that claims certain gender-affirming care is 'unsafe and ineffective' and threatens to exclude providers from Medicare/Medicaid for offering such care. The attorneys general argue HHS violated federal administrative law by implementing a major policy change without required notice-and-comment rulemaking, creating fear for patients and providers and threatening state Medicaid programs.
The coalition is asking the U.S. District Court for the District of Oregon to declare the HHS declaration unlawful and issue an injunction blocking its enforcement.
In-house legal teams should review all agreements where the entity is a healthcare provider, vendor, or contractor receiving Medicare/Medicaid funding or serving transgender patients. Focus on clauses governing compliance with federal healthcare regulations, termination rights, force majeure, change-in-law provisions, and definitions of covered medical services. Specific clauses to scrutinize include: (1) compliance certifications referencing federal program requirements; (2) termination clauses triggered by exclusion from federal programs; (3) service description clauses that define reimbursable or permitted care; and (4) indemnification or regulatory risk allocation provisions. Potential changes may involve adding language to address abrupt federal policy shifts, clarifying that service definitions follow prevailing medical standards rather than agency declarations, and negotiating cure periods or renegotiation triggers if federal funding or participation status is threatened.
Entity
U.S. Department of Health and Human Services (HHS)
Also known as: HHS
Industry
HealthcareOfficial Press Release
https://www.doj.state.or.us/media-home/news-media-releases/ag-rayfield-leads-lawsuit-challenging-attack-on-gender-affirming-care/
Oregon v Kennedy Complaint 25cv02409
https://www.doj.state.or.us/wp-content/uploads/2025/12/Oregon-v-Kennedy-Complaint-25cv02409.pdf
Oregon Attorney General Enforcement Page
https://www.doj.state.or.us/consumer-protection/
"U.S. Department of Health and Human Services"
"HHS is attempting to use the declaration to circumvent basic legal requirements for policy changes. Federal law requires agencies to provide the public with notice and an opportunity to comment before making significant changes to health care policy."
"Joining Attorney General Rayfield in this lawsuit are the attorneys general of California, Colorado, Connecticut, Delaware, the District of Columbia, Illinois, Maine, Maryland, Massachusetts, Michigan, Minnesota, New Jersey, New Mexico, New York, Rhode Island, Vermont, Washington, Wisconsin, and the governor of Pennsylvania."
Oregon Attorney General Dan Rayfield secured a temporary restraining order blocking Paramount Skydance Corporation's proposed $110 billion acquisition of Warner Bros. Discovery. The lawsuit, joined by 11 other state attorneys general, alleges the merger would harm Oregonians through higher prices, lower content quality, and reduced competition in film and television distribution.
$29.6M
Oregon Attorney General Dan Rayfield and a bipartisan coalition of states reached a $29.6 million settlement with Glenmark, a generic drug manufacturer accused of conspiring with other pharmaceutical companies to inflate prices and limit competition for numerous generic prescription drugs. The settlement requires Glenmark to cooperate in ongoing multistate litigations and implement internal reforms to ensure fair competition and antitrust compliance.
Oregon Attorney General Rayfield and a coalition of 11 other attorneys general filed a motion for a temporary restraining order and preliminary injunction to block the $110 billion acquisition of Warner Bros. Discovery, Inc. by Paramount Skydance Corporation. The lawsuit alleges the merger violates Section 7 of the Clayton Act by substantially lessening competition in theatrical film distribution and basic cable television licensing, which would lead to higher prices and reduced content quality for consumers.
$18.0M
A coalition of 42 state attorneys general settled bankruptcy claims against 23andMe following a 2023 data breach that compromised genetic data of 6.9 million customers. The settlement includes $150 million in allowed claims, with $18 million paid from bankruptcy funds, and requires enhanced data security measures for the successor entity, 23andMe Research Institute.
Oregon Attorney General Dan Rayfield and a coalition of 12 state attorneys general filed a lawsuit challenging the $110 billion acquisition of Warner Bros. Discovery by Paramount Skydance Corporation. The lawsuit alleges the merger violates Section 7 of the Clayton Act by substantially lessening competition in theatrical film distribution and basic cable television licensing, which could lead to higher prices and reduced choice for consumers.
The provided press release is a media release from the Oregon Department of Justice announcing a multistate press conference of attorneys general from Oregon, California, Washington, Nevada, and New York advocating for increased state resources to address antitrust enforcement gaps following reduced federal oversight. No privacy-related enforcement actions, violations, penalties, or remedies are described in the document.