INTRODUCTION: Respecting trans people's right to the highest attainable standard of health, and producing public policy in a context of crisis, are key contemporary global issues. This article examines the production of public policy through a specific analysis of the framing of transition pathways by the Haute Autorité de Santé (French National Authority for Health). PURPOSE OF THE STUDY: Drawing on the research frameworks of critical discourse studies and survivor research, the study applies lexicometric methods to the analysis of normative reference frameworks. Specifically, it focuses on the naming and argumentative strategies of both mitigation and intensification. RESULTS: Hierarchical top-down clustering using the ALCESTE method revealed a structure made up of three lexically distinct pairs. A similarity analysis revealed 31.6% of trigrams shared with the report by the Inspection Générale des Affaires Sociales (French General Inspectorate for Social Affairs). The differences and similarities observed appear to be neither random nor based on scientific evidence, and emphasize the psychopathologization of trans people to the detriment of their health needs. CONCLUSIONS: Our findings ask questions about health care system governance and, specifically, the production of public policy and norms. The document's structure suggests it is a product of political arbitration, freed from scientific constraints and designed to impose a psychopathological vision justifying control by the health care system. Critical analysis appears to be an effective approach for analyzing how public institutions operate in the context of crisis.