I'm a licensed mental health professional in the state of Virginia with a clinical focus in providing affirming care to trans and non-binary clients. I see first hand the need to update the ambiguous language of the current regulations around changes of sex on legal documentation. My understanding is that with the current wording of "when the sex of an individual has been changed by a medical procedure," it is up the discretion of the court to determine what medical procedure will be sufficient "proof." Unfortunately, this can mean that someone can be denied a change of sex on their documentation because a court determines that they are lacking a particular step in medical transition, such as surgery. This is wholly inaccurate and unfair. One problem is that even for those people who do desire surgery, access to this is impacted by financial ability and insurance coverage and thus the current regulation discriminates against those with less privilege. However, an even larger problem is that surgery is not and does not need to be part of everyone's medical transition. However, if a court requires this and denies someone's request to have their documentation changed despite the fact that the person is presenting as their identified gender, this will force them to be "outed" to those in authority when presenting documentation. This could jeopardize someone's safety as well as housing and job opportunities. Please update this policy to allow for easier access to life saving and affirming updates to one's sex as listed on legal documentation. Thank you!