Status: 🔴 Former ICE Enforcement and Removal Operations (ERO) executive and Trump border enforcement czar whose 2015 Transgender Care Memorandum — once ICE’s core protection for transgender detainees — was rescinded in April 2025 during the Kristi Noem rollback.
Thomas Homan is a career immigration enforcement official who served as Executive Associate Director of ICE’s Enforcement and Removal Operations (ERO), overseeing detention and removal operations. In June 2015, ERO issued the “Further Guidance Regarding the Care of Transgender Detainees” — known as the Transgender Care Memorandum — under Homan’s authority. The memo required ICE to screen detainees for gender identity, house transgender detainees according to their identity, and provide continued access to transition-related medical care, including hormone therapy.
Homan later served as Acting Director of ICE (2017–2018) under Donald Trump and returned in 2025 as Trump’s border enforcement czar.
In April 2025, under Secretary Kristi Noem, ICE rescinded the 2015 Transgender Care Memorandum, ending the protections it had established.
The Transgender Care Memorandum, issued while Homan led ERO, established ICE’s framework for the care of transgender detainees: recording gender identity in data systems, identifying transgender detainees early in the custody cycle, forming facility-based Transgender Care Classification Committees to decide housing, searches, and medical care, and continuing hormone therapy and other transition-related care based on medical need. The guidance was the result of a six-month agency working group.
On April 17, 2025, ICE directed staff to stop screening and recording gender identity and rescinded the 2015 Transgender Care Memorandum along with a 2022 Aurora directive, dismantling the protections Homan’s memo had established. Contract changes beginning in March 2025 had already cut transgender-related care in detention facilities.