NHS Public Consultation

An NHS Public Consultation on specialised gender identity services was launched in July and remains open for public response until October 16th, through their online survey here.

The new specification which alarms us is the proposal to lower the age of acceptance into adult services to 17 years.

Currently young people can be referred from the Tavistock child and adolescent clinic at age 17 years 9 months, to take into account waiting times for adult clinics. If the age of entry into adult services is reduced to 17, effectively this means that referrals from the Tavistock will be made at age 16.

We strongly oppose this change. The NHS does not acknowledge that it will disproportionately affect the unprecedented number of teenage girls being referred to the Tavistock clinic, nor that this is a new phenomenon for which no explanation has been proffered. To simply enable their faster passage to surgery without investigation we believe shows a lack of duty of care to this group.

Two of us went along to the NHS public consultation meeting on September 6th in London to voice our concerns: we asked what the rationale was for the drop in age to seventeen and whether rates of detransition and regret would be measured as an outcome. Although we were given time to make our points against the lowering of age, we did not get any clear answer to this question, only that there needs to be good communication and ease of transfer between services. Which is obvious, but not an explanation for the age drop. We had already heard that clinical policy has to be evidence-based but we were not informed of any evidence behind this proposal.

On the subject of detransition, the concept of regret itself was questioned. We were told that detransition is not necessarily a ‘failure;’ that re-transition may be a better way of looking at it and that many are happy that they transitioned as part of their ‘gender journey’ and have learned about who they are. The NHS does not fund ‘reversal’ of transition although we were told that testosterone-induced facial hair could be removed as part of a ‘second gender dysphoria event’ although it was not clear whether the NHS would fund this. The people who regret medical transition and describe their lives as having been ruined are absent from this picture and without this data the NHS cannot build up an accurate evidence base for medical transition of young people.

There is no indication that the NHS is looking at current research in order to develop robust evidence-based practice, such as this recent study by Bechard et al which would suggest more caution in the treatment of adolescents, not less:

“The findings supported the clinical impression that a large percentage of adolescents referred for gender dysphoria have a substantial co-occurring history of psychosocial and psychological vulnerability, thus supporting a “proof of principle” for the importance of a comprehensive psychologic/psychiatric assessment that goes beyond an evaluation of gender dysphoria per se.”

It seems that the NHS has replaced rigorous research and evidence with unquestioning acceptance of certain narratives promoted by trans activists. We witnessed at the meeting the pressure on the NHS coming from a vocal segment of the transgender community, with demands centred on the right to self-refer and the provision of assorted cosmetic procedures not currently offered on the NHS. The insistence that gender dysphoria is not a mental health issue leaves troubled young people in a vulnerable position whereby mental health problems cannot be explored at all in relation to their dysphoria. Psychotherapy is only offered for issues viewed as distinct from gender dysphoria, but not considered as a potential cause.

This is the problem created when a social justice issue intrudes into healthcare: there is no evidence that the NHS considers that there is any reason behind a young person presenting as transgender, other than that the person is transgender. There is no diagnostic procedure to untangle ‘gender dysphoria’ from underlying issues unconnected with ‘gender’ so that a diagnosis can be made with confidence. A 30 minute assessment is woefully inadequate for young people.

Our response to the consultation centres on how services currently offered in the adult gender identity clinics would affect not only seventeen year-olds, but more broadly the late teens and early twenties group as a whole. This is the age when young people can be away from home for the first time at college or university and are therefore negotiating new challenges, stresses and anxieties in their lives. We hear from parents, particularly of sons and daughters who are vulnerable in some way (ASD, previous trauma or mental health issues) whose involvement with LGBT societies at university leads to the sudden adoption of a ‘trans’ identity, accompanied by mental health deterioration.

This post details what is happening at universities in the US and we know from the parents who contact us that the picture is similar here in the UK, in that campus pastoral care and counselling services will offer nothing but ‘affirmation’ to a young person who has adopted a trans identity. ‘Coming out as trans’ is seen in exactly the same way as ‘coming out as gay.’ We all know the joke about ‘being lesbian at uni,’ in recognition that this is a time that young people experiment and sexual orientation is not necessarily fixed, but what protection does the NHS offer to young people who are going through a ‘being trans at uni’ phase, to ensure they do not take a medical pathway which will have irreversible effects on their bodies they may later regret? As ‘gay’ and ‘lesbian’ (especially ‘lesbian’) become increasingly uncool, more and more students will find that nothing less than an identity which requires medicalisation is good enough to get them into the LGBT community now dominated by queer and transgender activists.

It is therefore very worrying that the NHS consultation document states that “providers will not deliver, promote or refer individuals to any form of conversion therapy” which is defined as “a therapeutic approach, or any model or individual viewpoint that demonstrates an assumption that any gender identity is inherently preferable to any other.” In practice this means that any young woman identifying as a man must be affirmed as a man, and the same for any man who identifies as a woman. As ‘gender identity’ orthodoxy is already doing a very good job of encouraging young lesbians to view themselves as trans ‘straight guys,’ unquestioning affirmation can be viewed as a form of gay conversion therapy in itself. ‘Affirmation’ is an approach informed by ideology, not by research and evidence.

The NHS consultation document mentions “the small but growing number” of GPs who are unwilling to prescribe off label cross-sex hormones, which is unsurprising. An uncritical acceptance of a patient’s self-diagnosis followed by one set clinical pathway of invasive lifetime medical treatment, increasingly referred to as an ‘informed consent’ model, is unprecedented within medical practice. The British Association of Gender Identity Specialists pointed this out in their written submission to the government Transgender Equality Inquiry:

“The same phrase — “informed consent” — seems to the Association to have been borrowed by those suggesting a very radical and negative shift in medical practice. It is suggested that provided patients are of sound mind (this amounts to the exclusion of serious mental illness) and understand the nature and consequences of what they request it should, essentially, be the role of the practitioner to fulfil that request. Crucially, there seems to be no recognition or acknowledgement of the view of the practitioner concerned about the merit of the suggested procedure. If actually implemented, this arrangement would leave medical practitioners in the position of having to make diagnoses they do not believe in, prescribe drugs they personally believe will not benefit the patient and undertake surgical procedures that they themselves believe will confer no benefit or cause harm. This is incompatible with medical practice, the first tenet of which is that one should “first, do no harm”.”

Our response to the consultation document is quite detailed and can be viewed here. Because it is clear that the NHS have listened only to a small section of the trans community and use non-medical, non-scientific teaching materials from activist organisation GIRES, it is important that they also hear different views. Responses do not have to be long and detailed, but the Comments sections are a chance for everyone to air their views and ask some serious questions of the NHS. This is a public consultation; please do respond. The deadline is October 16.


This Post Has 6 Comments

  1. E

    Excellent, thoughtful reply. May foreigners comment?

    1. Transgender Trend

      There’s nothing that says they can’t! Please do. Thanks.

  2. ScaredMum

    Thank you so much for this very thoughtful and well considered response, and highlights the particular vulnerability of very young adults who are in fact still adolescents, even if over 18.

    Have you looked at this guidance for doctors carrying out cosmetic procedures:?


    These paragraphs could be particularly relevant to offering medical interventions based on a patient’s beliefs/desires:

    If a patient requests an intervention, you must follow the guidance in Consent, including consideration of the patient’s medical history. You must ask the patient why they would like to have the intervention and the outcome they hope for, before assessing whether the intervention is appropriate and likely to meet their needs.
    18 If you believe the intervention is unlikely to deliver the desired outcome or to be of overall benefit to the patient, you must discuss this with the patient and explain your reasoning. If, after discussion, you still believe the intervention will not be of benefit to the patient, you must not provide it. You should discuss other options available to the patient and respect their right to seek a second opinion.
    19 When you discuss interventions and options with a patient, you must consider their vulnerabilities and psychological needs. You must satisfy yourself that the patient’s request for the cosmetic intervention is voluntary


  3. Miranda Myers

    As the mother of a 15 year old ‘trans identified’ daughter I wholeheartedly agree with every point made here.

  4. Shocked Mom

    I am the mother of a daughter who self identified as “trans.” She has mental health issues with anxiety and depression and I am shocked at the health professionals who do not even question this rapid onset of a new identity. I think it is criminal that hormone therapy and body altering surgery is being encouraged. What happened to a physician’s pledge to do no harm? There needs to be a whole lot more research and evidence before these drastic measures should be provided especially when there are mental health issues involved. How can a child decide to do these things without anyone even questioning it when it is a known fact that the brain is not fully developed before the age of 25?? We won’t let them drink alcohol until age 21 in the US and they can’t rent a car until the age of 25 but they can decide to alter their bodies with hormones and surgery? This is ludicrous!

  5. Bonnidrasco

    It is quite within reason for a medical professional to deny cross sex hormones. After all, they generally not licensed for such. It is a biological impossibility to change sex and as such the normal stated self diagnosis and desired outcome is not going to be possible in any way shape or form. They (particularly adults) need to be told this in no uncertain terms and sent away so medical professionals can deal with genuine illness. If they subsequently present with mental health problems that can be dealt with appropriately. Children of course should be treated more sympathetically and worked with by carefully selected counsellors until they grow out of it.

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