WSPWG Letter to NCAA Board of Governors

Women's Sports Policy Working Group

Women’s Sports Policy Working Group (WSPWG) Endorses American Swimming Coaches Association’s (ASCA) Position and Encourages NCAA to Revise Its Transgender Guidelines 

Swimming World is publishing the following letter submitted by the WSPWG to the NCAA Board of Governors.

The Women’s Sports Policy Working Group endorses the American Swimming Coaches Association’s position, urging the NCAA to update its Transgender Eligibility Guidelines.  These guidelines, adopted in 2011, should ensure that the eligibility rules are evidence-based and do not undermine the fairness, equality, and safety goals that justify separate sex competition.  

In contrast with the NCAA’s prior process that was closed to stakeholders, the NCAA must involve female athletes who are not transgender, their coaches, and scientific experts in sex differences in human performance alongside transgender athletes and their advocates. 

The WSPWG believes that all transgender women, including Lia Thomas, should compete head-to-head in women’s events, if they can demonstrate that they’ve rolled back the sport advantages that result from male puberty, and are no longer benefitting from the structural and physiological effects of circulating testosterone outside of the female range. 

As the table below and preliminary scientific analysis demonstrates, Lia is overperforming in women’s events. Her post-transition times to date – especially in the 200 yd and 500 yd freestyle  – remain too close to her pre-transition bests in men’s events relative to the performance gap between male and female athletes in Ivy League and NCAA D-1 competition. Based on NCAA 

historical performance data and what we know about the effects of testosterone suppression,  these differences are unlikely to be the result of normal development over time, including male-typical training gains in the collegiate cycle. 


LT PRE-Transition  

’18-’19 Personal Best Time & Ranking  

In Men’s Events

LT POST-Transition  ’21-’22 To Date 

Time & Ranking  

in Women’s Events (as of 1-17-2022)

% Gap  

LT Pre- & Post 


% Gap  




Male to Female

200 yd Free 


# 462 in the nation


# 1 in the nation

2.64%  11.87%
500 yd Free  4:18.72 

# 65 in the nation


# 2 in the nation



1650 yd Free  14:54.76 

# 32 in the nation


# 6 in the nation




Had testosterone suppression worked to roll back Lia’s male sex-linked advantages, we would have expected to see the gap between her performances in men’s and women’s events grow at least to approximate the gap between males and females generally. Because it did not, Lia has gone from being a strong but not exceptional performer in D-1 men’s events to being a national contender in D-1 women’s events.  

Moreover, consistent with the data on the performance gaps across the distances swum, and the scientific evidence on the differential effects of testosterone suppression on endurance versus explosive power, Lia’s times in endurance events have dropped more significantly than her times in the sprints, and she is a much better sprinter post-transition than she was pre-transition.

We have no reason to doubt Lia’s word and her institution’s representation that she is eligible  for team membership under the NCAA’s current rules, which require transgender women first to  complete at least “one-year of testosterone suppression treatment.”  

However, that standard was based on the hypothesis that one year of testosterone suppression would be sufficient to roll back a transgender woman’s male sex-linked performance advantages,  or that waiting longer wouldn’t diminish those advantages further enough to justify holding an athlete out beyond that point. According to the hypothesis underlying the NCAA’s rule, rolling back male performance advantages should close the performance gap and result in an included athlete at least more-or-less returning to her place in the ranked hierarchy. For example, taking into account possible changes in an athlete’s ranking overtime – changes that could come from normal development, training gains, injury, and other life circumstances – if she had been ranked around 5th in the nation as a male competing in the men’s division, one would expect she should be ranked around 5th in the league or in the nation in the women’s division after a year of testosterone suppression.  

These assumptions are what made the NCAA’s inclusion standard presumptively fair to individual female athletes and protective of the female category in general. They were to have ensured that a transgender athlete’s performance in women’s events wasn’t boosted by ongoing or residual male sex-linked advantages and that moving from the men’s to the women’s division didn’t materially change how good an athlete is relative to her competitors.  

The WSPWG assumes that in adopting its rule, the NCAA did not intend to sacrifice fairness to female athletes and the integrity of women’s sports by including transgender women whose physical transition was clearly insufficient. 

The WSPWG has consistently supported the NCAA’s efforts to include transgender women in female events who have mitigated their male sex-linked performance advantages. It has also consistently supported the NCAA’s efforts to align its rules with those that apply in post-collegiate competition. Harmonization is important to ensure that American athletes can move successfully across the collegiate, Olympic, and professional sports systems. But new scientific evidence and results like Lia Thomas’s demonstrate that these rules need to be updated.  

Going forward, the WSPWG encourages the NCAA to develop a transparent, representative process to ensure that its transgender eligibility rules are evidence-based and don’t undermine the fairness, equality, and safety goals that justify the women’s category. To these ends, we recommend specific attention to the following: 

  1. Consultation with recognized experts in sex differences in human performance, physiology,  cardiology, and endocrinology. 
  2. Consideration of the differential effects of testosterone suppression depending on the age at which treatment is begun, and on different sports and events. 
  3. Consideration of the details of the suppression requirement. To date, to our knowledge, the rule does not specify that transgender women must suppress their testosterone levels into the female range, nor does it require that they keep their levels within that range throughout athlete’s competitive collegiate career. These conditions are necessary if mitigation is possibly to be effective. They are also necessary if the mitigation requirement is to be fair. A system that,  under its eligibility rules, allows a transgender woman to tailor her testosterone levels according to her personal preferences but then, under its anti-doping rules, prohibits female athletes from doing the same, is not fair. The NCAA should align the doping and transgender eligibility rules,  and clarify the details of the suppression requirement accordingly, so that transgender athletes do not have the advantages the anti-doping rules properly prohibit to female athletes, and so that the outcome of female competitions isn’t determined by the traits the category was designed to exclude. 
  4. Adoption of a monitoring protocol to ensure compliance with the testosterone suppression requirement. The NCAA should rely on the necessary certifications concerning timing, levels, and consistency, reported by the athlete’s treating endocrinologist to ensure monitoring is not unnecessarily intrusive. 
  5. Respectful accommodations for transgender athletes who have been included on teams but are periodically ineligible. Accommodations might include offsets, e.g., an extra exhibition lane, separate scoring and events, or team or individual handicaps, depending on the sport and event. Accommodations should be developed by experts in the affected sports and events. 

Women’s sports are separate from men’s because of the physical, sex-linked differences between males as a group and females as a group. There is no alternative, defensible, non-sex linked rationale for separate sex sport. Recognizing, respecting, and accommodating categorical sex-linked differences ensures that sport meets its social justice obligations to both female and transgender athletes, enables fair and safe competitive sport, and secures the integrity and viability of female sport. 

The consideration of these comments by the NCAA Board of Governors is appreciated.

– – – – – –


Donna de Varona, OLY. Two-time Olympian and double gold medalist in swimming. In 1965, UPI and AP  voted her outstanding woman athlete in the world after she set 18 world records and fastest times. She was a sports broadcasting pioneer, the youngest and one of the first women to work in the industry. An  Emmy recipient, she used her visibility to advise and advocate for the protection and promotion of Title  IX and the Ted Stevens Olympic and Amateur Sports Act. As the first President and Chair of the Board of the Women’s Sports Foundation, she helped build the organization into a sustainable, influential entity. She has served on five presidential commissions and is a member of the Seneca Falls Women’s Hall of  Fame. Currently, she is a member of the International Olympic Committee Communications Commission, and was recently voted onto the U.S. Olympic and Paralympic Committee Board of Directors. 

Martina Navratilova, OLY. Former professional tennis player and coach. In 2005, Tennis magazine selected Navratilova the greatest female tennis player for the years 1975 – 2005. She is considered one of the best female tennis players of all time. Over her career, she won 18 Grand Slam singles titles, 31 Grand  Slam women’s doubles titles (an all-time record), and 10 Grand Slam mixed doubles titles, for a combined total of 59 major titles, marking the Open Era record for the most Grand Slam titles won by one player,  male or female. Coached later in her career by the first trans-woman tennis player, Renée Richards, and long active in LGBTQ rights work and with the women’s tennis tour, Navratilova is particularly well-positioned to contribute to thoughtful policy on the inclusion of trans women/girls in women’s sport. 

Donna A. Lopiano, Ph.D. President and founder of Sports Management Resources, LLC, Adjunct Professor of Sports Management, Southern Connecticut State University, former Chief Executive Officer of the  Women’s Sports Foundation (1992-2007), Director of Women’s Athletics, University of Texas at Austin  (1975-1992). President of The Drake Group—an organization focused on academic integrity in college sport. A Title IX sports pioneer, Lopiano specializes in gender equity in the educational and Olympic and elite sports spaces. As an athlete, she participated in 26 national championships in four sports and was a  nine-time All-American at four different positions in softball, a sport in which she played on six national championship teams. 

Nancy Hogshead-Makar, J.D., OLY, CEO Champion Women, civil rights lawyer, two-time Olympian, three-time gold medalist and one silver in swimming, U.S. National Team for eight years, 12 Halls of Fame,  including the International Women’s Sports Hall of Fame and the International Swimming Hall, 20 years of teaching Sports Law and Administration, current Professor at Rutgers University’s Global Sports  Business MS Program. Women’s Sports Foundation – President 1991-1993, Legal Advisor, 2003-2010,  Senior Director of Advocacy, 2010-2014. 

Tracy Sundlun, CEO, Everything Running, Inc., Founding Board Member, National Scholastic Athletics  Foundation. Co-Founder and original Director of the National Scholastic (High School) Indoor & Outdoor  Track & Field Championships (1984 – Present). Co-Founder, Rock ‘n’ Roll Marathon Series, at the time the largest running series in the world with over 500,000 participants annually in 29 events in 7 countries  (1998 – 2016). Former club and collegiate track coach (including Georgetown, Colorado, USC), guiding over 100 men and women in every event from 15 countries competed in the Olympic Games and international competitions. Six-time Olympic Coach and Manager (1972 – 2016). Inducted into Running  USA Hall of Champions. 

Contact Information: 

Donna A. Lopiano 


452 Fisher Court, Shelton, CT 06486

All commentaries are the opinion of the author and do not necessarily reflect the views of Swimming World Magazine nor its staff.

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2 years ago

How about sex based competition, based on biological sex? Two sexes, two categories, male & female. Including biological males in the female category will never be fair to females. Fairness to the majority. Create a new category for males on hormones. Do we want to crate a Harrison Bergeron society? I say no.

2 years ago
Reply to  Laurie


A Real Woman
A Real Woman
2 years ago

How about NO. They’re MEN and can play on the men’s team. This woman and girl hating ideology needs to go away. Stop trying to appease the Nazis regime and stand up for females.

2 years ago

Great thoughtful article!

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