Comment on DOS-2026-0694-0008

Specific Concern: Section 3, Previous Surgeries "List all previous surgeries, including but not limited to those related to other health conditions, heart disease, pregnancy, or elective surgeries to attempt to change male traits to female and vice versa." This language is overly broad and singles out gender-affirming surgery by name, while other elective procedures are folded into a vague "including but not limited to." A few concerns: Necessity: Previous surgeries matter when they affect current health, complications, or ongoing treatment — not simply because they occurred. Privacy: If this extends to photographs of surgical outcomes involving genital or breast sites, it raises serious dignity and confidentiality concerns. Such sensitive information should only be collected with a clear medical justification and defined safeguards. No principled limit: If elective surgery is relevant because it changes appearance, the same logic would apply to piercings, cosmetic procedures, or permanent makeup — none of which bear on public health risk. Medical ethics require collecting only information that is relevant and necessary. Mandatory disclosure of sensitive health data should meet standard privacy principles: legitimate purpose, medical necessity, relevance, proportionality, purpose limitation, and data minimization. The government should be able to show a clear link between this specific requirement and a lawful public health objective.