Disclaimer: Previous articles have been based on documents and original reporting. This one is based on math and reasoning from available numbers, many of which are estimates at best. What follows is a theory, not a factual claim. I am presenting this as a question that deserves further investigation. Take this as speculation.

Does America have a mandatory reporting crisis for female genital cutting?

Before I discovered that two physicians federally prosecuted for FGM still hold active, unrestricted Michigan medical licenses, I was researching mandatory reporting around female genital cutting.

Given that certain populations have majority female genital cutting rate and those populations are growing in the United States, then it follows that there should also be high mandatory reporting rates from doctors who see those populations.

I assumed that the first federal prosecution of FGM in the United States would have some information on this and went to look up how the medical license was taken in that case… only to discover it wasn’t. That lead to the six month investigation you can read in detail here:

However, the original mandatory reporting question remains unanswered.

Summary

Based on the available numbers, here is what the math shows:

390,000 women/girls in the U.S. estimated living with FGM
31,000 girls under 18 at risk.
39,000 OB/GYNs have likely seen it clinically.
30,000 doctors in a position to have filed a mandatory report on a minor.
Failure to report suspected child abuse is a crime in 46 states, typically a misdemeanor punishable by up to a year in jail and fines up to $5,000.
There are essentially zero at the national level.

That means approximately 30,000 doctors might have failed to fulfill a legal obligation to report suspected abuse of a minor, which carries criminal penalties in nearly every state.

How I arrived at those numbers:

Here is the math behind that.

Skip if you’re just here for the commentary, but read in detail if you want to check my numbers.

Survivors

The 2023 AHA Foundation/Orchid Project analysis, Female Genital Mutilation/Cutting in the United States, identified 1,325,989 U.S. women and girls with ancestry or birthplace links to countries or communities where FGM is practiced. Using American Community Survey data, country-of-origin prevalence rates, age-at-cutting data, and migration and acculturation adjustments, the study estimated that 384,714 of them are living with FGM. A separate estimate of approximately 5,500 Dawoodi Bohra women and girls, calculated from congregation and community size rather than the ACS method, brings the central estimate to about 390,000.

That is roughly 0.23% of all women and girls in the United States.

384,714 + 5,500 = 390,214
390,214 ÷ 172,601,353 U.S. women/girls = 0.23%

Minors at risk

The same study estimated 30,956 girls under 18 are still at risk of FGM. These are the cases most directly relevant to mandatory reporting — a minor who has undergone FGM, is suspected to have undergone it, or faces credible risk.

30,956 ÷ 73,483,744 U.S. minors = 0.04% of all minors
30,956 ÷ 35,800,000 U.S. girls under 18 = 0.09% of girls under 18

This figure likely undercounts. Girls cut in infancy — common in some Nigerian and Indonesian communities — are modeled as already living with FGM rather than “at risk,” so they don’t appear in the 30,956.

Doctors who have seen it

A national survey of OB/GYN physicians published in 2021 found that 66% of clinically active respondents had cared for a patient who had undergone female genital cutting. The AAMC counts 58,739 professionally active OB/GYNs in the United States.

58,739 × 0.66 = 38,768

Roughly 39,000 OB/GYNs have likely treated at least one FGM survivor in a clinical setting where the cutting would be visible — pelvic exams, pregnancy care, delivery, cervical screening.

A broader estimate using CDC physician visit rates (320.7 office visits per 100 people per year) and the survivor population suggests the total number of physicians who have encountered at least one FGM patient could range from 100,000 to 250,000. I use the OB/GYN figure because it is the cleanest — it comes from an actual survey rather than modeling.

390,214 survivors × 3.207 visits/year = 1,251,416 physician visits/year
1,251,416 ÷ 12 visits per physician = ~104,000 physicians (low end)
1,251,416 ÷ 5 visits per physician = ~250,000 physicians (high end)

Doctors in a position to report

Not every physician who sees an adult survivor has a mandatory reporting obligation. Mandatory reporting is most clearly triggered when a minor is involved. Modeling from the at-risk minor population, the number of direct-patient-care physicians, and the likelihood of clinical contact produces a central estimate of about 30,000 doctors who have been in a position where a mandatory report involving a minor and FGM could reasonably have been expected.

30,000 ÷ 1,032,365 active U.S. physicians = 2.9%
30,000 ÷ 866,460 direct-patient-care physicians = 3.5%

Population denominators

U.S. total population: 341,784,857
Female share: 50.5% → 172,601,353
Minors (under 18): 21.5% → 73,483,744
Girls under 18: 73,483,744 × 0.487 ≈ 35,800,000
Active U.S. physicians: 1,032,365
Direct-patient-care physicians: 866,460

Sources

AHA Foundation/Orchid Project, Female Genital Mutilation/Cutting in the United States (2023); CDC/Public Health Reports, updated estimates (2016); U.S. Census Bureau QuickFacts; AAMC 2025 Key Findings: Physician Specialty Data Report; PubMed, national OB/GYN survey on female genital cutting care experience (2021); CDC/NCHS FastStats, physician office visits; Child Welfare Information Gateway, Mandatory Reporting of Child Abuse and Neglect.

Caveats

The United States does not directly count FGM survivors. Every number above is an estimate derived from indirect methods — ancestry data, country-of-origin prevalence rates, survey responses, modeled visit rates. The survivor count applies source-country prevalence to diaspora populations, which may not reflect actual prevalence among immigrants and their U.S.-born children. The physician estimate relies on a single specialty survey extrapolated to the broader physician population. No national database tracks mandatory reports filed specifically for FGM. I am presenting these numbers because the scale of the gap between estimated physician exposure and known reporting demands the question, not because the numbers are precise.

Where is the mandatory reporting?

If the above math is correct, then even on the low-end, there should be thousands of mandatory reports from physicians around FGM. Where are they?

I don’t have data to answer that. There is no national database tracking mandatory reports filed specifically for FGM. State child protective services agencies track reports by category, but FGM is not consistently broken out as a separate category in most states. The reporting infrastructure is not designed to track this.

But the absence of data is itself informative. Federal prosecutors in United States v. Nagarwala alleged that as many as 100 girls were cut at a single clinic over twelve years. The case was discovered not because a physician filed a mandatory report but because of a tip to law enforcement. No medical organization I contacted would say that physicians who perform FGM on children should lose their medical licenses. The American Medical Association condemned FGM in the abstract but declined to say whether the specific physicians charged should be disciplined. The Federation of State Medical Boards refused to condemn genital cutting on children. Eight other organizations did not respond at all.

If the estimates are even roughly correct, the scale of the gap is difficult to explain as anything other than systemic. Thirty-one thousand minors at risk. Thirty thousand physicians in positions to report. A practice that is a federal crime under the STOP FGM Act of 2020 and illegal in most states. Yet a near-total absence of reporting.

The Michigan case I’ve documented provides one answer for how this happens. A licensing board authorized an investigation and then never assigned an investigator. An attorney general’s office recommended closure while the evidence was still being gathered. A complaint calling the practice “torture” was dismissed through a citation to a file that had no investigative authority. Board members were not even notified of the outcome. Two physicians whose case generated the first federal FGM prosecution in American history now practice together at a clinic in Detroit, accepting patients, their licenses renewed without review.

That is one state. One case. Two physicians. And it took more than a hundred FOIA requests, multiple appeals, and a six-month investigation to document what happened. If the system failed that completely for a case that made national headlines, the question is: What is happening with the thousands of cases that didn’t?

Is there a systemic failure to report female genital cutting by those in the medical system? No one has investigated that question yet.

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If you’d like to support this work, you can contribute here: Expose Medical Board for Licensing an FGM Doctor

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