As community advocate for transgender people, I support this amendment. This update to the Vital Records regulations is in accordance with best practices for a modernized policy, and follows the professional expertise of organizations such as the American Psychological Association, the American Psychiatric Association, the American Medical Association, and the World Professional Association for Transgender Health (WPATH), which makes clear that gender transition is an individualized process that is not the same for all transgender people; and, a surgery requirement does not align with current understanding in transgender health care.

Additionally, the Vital Records regulations should allow for gender change upon submission of a statement from a licensed provider, rather than requiring a court order. Forcing people to discuss their gender identity and any medical treatment they have undergone in open court can cause significant discomfort and be psychologically traumatic. Further, the expense of securing legal counsel is beyond the means of many transgender people, a significant number of whom are unemployed or underemployed because of employment and education discrimination. Taking the gender change process out of the courts and placing it into the hands of the vital records agency will bring consistency and efficiency to the process, and also has the benefit of reserving court resources for more appropriate matters.