Bureau of Prisons to house transgender prisoners according to their "biological sex." Treating prisoners as members of the gender with which they identify "would be appropriate only in rare cases." This reverses guidance created by the Obama administration in 2012, and it conflicts with the Prison Rape Elimination Act of 2003. In 2018, the Cibola County Correctional Center in New Mexico operated a unit for transgender women; the women were housed together regardless of the reason for their detention. The building served as a federal prison, county jail, Immigration and Customs Enforcement detention, and housing for asylum-seekers. Reporters were granted access for the first time in June 2019; there were 27 inmates at that time. Defining gender as sex: On October 21, 2018, The New York Times revealed a Department of Health and Human Services memo that planned to establish a definition of gender based on sex assignment at birth across federal agencies, notably the departments of Education, Justice, and Labor, which, along with Health and Human Services, are responsible for enforcing Title IX nondiscrimination statutes. The Justice Department would have to approve any new definition that Health and Human Services might suggest. The memo argued in favor of a definition of gender "on a biological basis that is clear, grounded in science, objective and administrable" and the government's prerogative to genetically test individuals to determine their sex. Over the following days, thousands of protesters gathered in Washington, D.C.; San Diego; Portland, Maine; Minneapolis; Los Angeles; Milwaukee; Boston; and other cities across the country, and on November 2, nearly 100 lawmakers signed a letter to HHS Secretary Alex Azar asking him not to implement this change. On July 8, 2019, the State Department created the Commission on Unalienable Rights to initiate philosophical discussions of human rights that are grounded in the Catholic concept of "natural law" rather than modern identities based on gender and sexuality. Most of the twelve members of the commission have a history of anti-LGBT comments. Healthcare: Since 2016, the Department of Health and Human Services (HHS) has explicitly interpreted the word "sex" in the nondiscrimination provisions of the Affordable Care Act (Section 1557) to recognize and include transgender people, entitling them to the same services to which everyone else is entitled, although a federal court injunction on December 31, 2016, prevented HHS from enforcing its nondiscrimination rule. Under the Trump administration, HHS lawyers began working on