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We welcome the new interim service specification released by NHS England for the regional gender services that will replace the Tavistock Gender Identity Development Service (GIDS) next year. This is a massive departure from the previous NHS service specification. Gone is the ideological language, replaced by proper clinical considerations and a normal standard of care consistent with other child and adolescent services. This is what we have campaigned for.

Based on the interim report by Dr Hilary Cass, the new NHS service specification will cover the changeover period and provide support for current GIDS patients and those on the waiting list.

NHS England is holding a public consultation to seek views on the new specification which will run until 4^th December 2022.

Phase 1 of the service transformation service will be operational until a new service specification – Phase 2- is formed in 2023/24 following final advice from the independent Cass Review.

The new service specification will replace the previous NHS service specification released in 2016 (see our response here) and reviewed in 2019.

The previous version was heavily influenced by transgender lobby groups such as GIRES, along with the WPATH standards of care, reflected in the ideological language and concepts peppering the specification. The new version moves the service back to where it belongs, within child and adolescent paediatric and mental health services.

Overall, the new service specification recommends a watchful, careful exploratory approach tailored to the needs of each individual child/adolescent.

The new specification establishes that:

• Gender incongruence or distress may be a transient phase leading to a range of different outcomes.

• There is a high incidence of co-existing mental health/neurodevelopmental complexities in a significant number of children, requiring careful exploration.

And recommends that:

• The service is provided by established paediatric units with a strong partnership with mental health services, a strong track record of research in children and robust safeguarding frameworks in place.

• The primary intervention is psychosocial/psychological support and intervention.

• Individual care plans are based on a standardised approach to assessment and diagnosis.

• The approach is open to exploring all developmentally appropriate options for children.

• There is built-in support for local services through professional liaison and collaboration to meet the wider needs of children and young people.

• The service will take part in continuing data collection.

We are pleased to note that:

• Children will only be referred to the service through medical health professionals, not through schools, colleges or lobby groups.

• Children and their families will be strongly discouraged from accessing unregulated sources and providers of hormone treatments.

• Social transition is recognised as an active intervention needing careful consideration in each individual case.

• The Multidisciplinary Team will include professionals with expertise in child safeguarding, child and adolescent development, autism and children who are in the care system, and the team will have understanding of the wider social context and contested debate.

• Puberty blockers will only be prescribed within a formal research programme with adequate follow-up into adulthood.

This new service specification represents a hugely significant change in NHS England’s approach to children and young people suffering gender dysphoria and distress. We would have been very happy if this had been the response to our full submission to the service specification consultation in 2016. Children should never have been medically treated by the NHS on the basis of the political demands of adult activists peddling an ideology. The ‘gender affirmative’ approach has harmed children. It is time to apply normal levels of scrutiny to the influence these organisations still have in schools, social services and children’s organisations, in line with the new NHS approach.

The new specification has huge implications for schools. No child should now be socially transitioned in school without consultation with the clinical professionals who are supporting that child, along with parents or carers. The service specification makes very clear that teachers are not qualified to make this decision. The Equality and Health Inequalities Impact Assessment attached to the service specification clarifies that children referred to GIDS do not share the protected characteristic of ‘gender reassignment’ as a class or cohort of patients:

“To apply such a definition to these individuals is to make assumptions upon the aims and intentions of those referred, the certainty of those desires and their outward manifestation, and upon the appropriate treatment that may be offered and accepted in due course.”

Schools should not be pre-empting the service by unilaterally making such decisions about individual children.

There are three questions that immediately arise from reading through the service specification:

1 . The majority of referrals to GIDS are adolescents, predominantly girls, but the number drops off at age 17 because this group waits for referral to adult services. There urgently needs to be an adult service transition pathway that continues the level of care provided in child and adolescent services until the mid-twenties when the brain reaches its full development. Currently older teens and young adults go into an adult service that replicates the failings of the Tavistock GIDS through its ‘gender affirmative’ approach without holistic assessment and consideration of significant factors influencing the young person’s development of gender dysphoria. (See our submission to the public consultation for the adult service specification in 2017 here).

2. The campaign by lobby groups and some health bodies for ‘transgender’ to be added to the government’s proposed conversion therapy ban is in direct contradiction of the findings of the Cass interim report and the new NHS service specification. The simplistic idea of ‘conversion’ of a child’s transgender identity undermines the necessary explorative approach outlined here. NHS England needs to reconsider its position as a signatory of the Memorandum of Understanding on Conversion Therapy which is incompatible with the new service specification.

3. The Sandyford clinic in Glasgow has undergone no independent review. How can NHS England and NHS Scotland operate such different services for the same cohort of children? If children in England and Wales deserve the best level of treatment and support, what about Scottish children? NHS treatment pathways should be based on clinical evidence, not politics. Where does this new NHS service specification leave Scotland?

We urge everyone, including parents, detransitioners, teachers and health professionals, to submit your response to this very important public consultation.

Submit your response here:

https://www.engage.england.nhs.uk/specialised-commissioning/gender-dysphoria-services/