Some thoughts on the Levy Review

On 18 December, NHS England quietly published the report of Dr David Levy’s review of adult gender clinics. The report’s official title is the massively dry Operational and delivery review of NHS adult gender dysphoria clinics in England, but it’s commonly referred to the “Levy Review” within community spaces.

Prior to its publication, there were some concerns about the Levy Review being a sort of Cass Review for adults, leading to further massive restrictions in trans people’s access to healthcare. I witnessed active catastrophising in some quarters, with social media posts calling medication stockpiling. I don’t think this kind of rollback was ever on the cards with Levy, but I do understand why people were concerned. Trans people’s trust in the NHS and political processes is – justifiably – at rock bottom.

There were also a minority who hoped that the Levy Review might result in significant improvements to how trans people are treated by the NHS in England. I don’t think that was ever realistic either.

In reality, Levy does acknowledge some of the problems with English gender clinics, focusing especially on capacity issues, inefficiencies, and long waiting times. It offers a series of recommendations relating largely to the practical operation and delivery of gender services (the hint is in the title!) QueerAF asked me what I thought about it for their coverage of the Levy Review, and I told them this:

“Faced with the sinking Titanic of trans healthcare in England, the Levy Review suggests we rearrange the deckchairs,” Dr Ruth Pearce, a transgender health expert and Senior Lecturer in Community Development at the University of Glasgow, tells QueerAF. Levy's report offers a limited, technocratic response to the ongoing crisis, recommending a range of bureaucratic measures to improve the efficiency of the current system.


These measures may still result in a few improvements. NHS England hope Levy’s recommendations will contribute to “clinical effectiveness, safety, and experience”. I am not entirely convinced. But perhaps the waiting lists can be a bit shorter and fairer, especially with the opening of new clinics and introduction of a national waiting list.

Why is the Levy Review like this?

Levy did not truly seek to understand, let alone confront, the real scope of the problem in trans healthcare services, sticking instead to the very narrow scope of the brief provided by NHS England. Deeper issues he ignored include open discrimination from healthcare practitioners, as well as gatekeeping, pathologisation, and dehumanisation baked into the design of the gender clinics. These all harm patients, while also wasting clinical time and resources.

When I started my PhD on trans healthcare in 2010, such issues were not widely understood outside of certain trans community settings. That is no longer the case.

There have been multiple reviews and consultations undertaken by NHS England over the past 15 years, including in 2012, 2014-2015, and 2017-2019. There was also a review undertaken by the House of Commons Women and Equalities Committee in 2015.

Then there’s the research I undertook for that PhD, later published in my book Understanding Trans Health. Here, I argued that long waiting lists for gender clinics are not simply a result of underfunding or bureaucratic inefficiencies, but also an inevitable outcome of the gatekeeping system. By positioning trans healthcare as a specialist matter, and forcing patients to prove over and over again in psychiatric evaluations that they are “really” trans, you create unnecessary roadblocks and bottlenecks for care.

There have been a lot of other studies undertaken since. The most notable might be the massive, rigorous, and extremely detailed final report of the Integrating Care for Trans Adults (ICTA) project, published in 2024. This was funded by the UK government through the National Institute for Health Research, and has been roundly ignored by NHS England.

There are also a growing number of popular analyses: blog posts, news stories, podcasts, and video essays. One prominent example is I Emailed My Doctor 133 Times: The Crisis In the British Healthcare System, by Philosophy Tube, which has been seen by over 2.5 million people to date.


All this research and commentary highlights those same problems ignored by Levy: discrimination, gatekeeping, pathologisation, and dehumanisation.

My feeling is that neither NHS England nor Levy were interested in these issues. In fact, they are not really interested in understanding trans people at all.

It is therefore no surprise that Levy not only ignores widely-documented problems, but also repeats factually inaccurate claims, such as that the growth in patient demand for gender clinics is “not well understood”. Quite aside from what we have learned from all of the research and commentary noted above, this growth was forecast back in the 2000s by the education and advocacy organisation GIRES, in a study funded by none other than the Home Office.


The really bad stuff (and how to protect your data)

For all the limits of the Levy Review, I feel most of the recommendations are somewhat positive and may help people a bit. On balance, it’s mostly okay.

However, there are a few real points for concern.

Firstly, Levy argues that a first assessment for medical interventions should always be undertake by a psychiatrist or clinical psychologist. As all the research on trans healthcare services has shown time and time again, this is both unnecessary and unhelpful. It compounds the pathologisation of trans people, wrongly positions trans healthcare as a “specialist” matter, and creates expensive bottlenecks for treatment.

Secondly, Levy insists that gender clinic patients should be referred by GPs, and should not be able to self-refer. This is intended to help with the problem of patients ending up on a waiting list with no information for clinical staff on who they are, what they are looking for, and what their healthcare needs might be. However, the recommendation ignores the widespread issue of transphobic GPs refusing to provide referrals, as well as the fact that not everyone will have a GP (see, for example, the fact that trans people disproportionately experience homelessness, or that we are more likely to avoid healthcare providers due to justified fears of abuse). The problem Levy is trying to address could have been tackled in a more sensitive way, for example through NHS England providing a short referral form that prospective patients can fill in when seeking an appointment at a gender clinic.

Finally, there is the issue of future research. Citing Alice Sullivan’s transphobic report on sex and gender, Levy calls for more data collection on patient outcomes. Here Levy fails to acknowledge the urgent need to build trust before trans patients can be confident the NHS will not misuse our data. Moreover, as Trans Safety Network have noted, NHS England have committed to addressing this through expanding the role of the National Research Oversight Board for Children and Young People’s Gender Services. Trans Safety Network report that the board includes members associated with anti-trans medical groups, including the Society for Evidence-Based Medicine (SEGM), who are listed as a hate group by the Southern Poverty Law Center, and CAN-SG. It’s little surprise therefore that the National Research Oversight Board has recommended that clinicians working with young trans people attend SEGM and CAN-SG conferences, ensuring the further spread of transphobic disinformation, pseudoscience, and hate.

Trans Safety Network therefore recommend that trans patients in England opt out of their healthcare data being used for research. They provide the following advice on opting out:

This can be done via the following links, the first to stop GP records being shared and the second to stop secondary care records being shared.

We also suggest you email your GIC the following to ensure your opt-out is clear and ask to have a note of this added to your care record. I do not give my permission for any aspect of my patient data to be submitted to, or collected for, the purpose of any research or non local audit without my express permission in writing being obtained in advance.

Emails should include your name, DOB and NHS Number to assist your GIC admin in finding your record. If you have been referred but not been seen by a GIC, you can still contact the GIC you were referred to.


Could it be better?

The failings of the Levy Review are not inevitable. There are numerous international models of better practice. For a strong example, see the Professional Association for Transgender Health Aotearoa’s 2025 Guidelines for Gender Affirming Care in Aotearoa New Zealand. This recommends treatment under an “informed consent” model. Here is some of their guidance on this for adult patients:

Being transgender is not a mental illness, and it does not impair capacity to consent to treatment. If a doctor or nurse practitioner has sufficient knowledge, skill and professional scope to initiate GAHT [gender-affirming hormone therapy] in an adult patient:

– There is no requirement for all people to be assessed by a mental health professional prior to starting GAHT

– For many transgender adults, GAHT can be initiated in primary care, without the involvement of secondary or tertiary care.

But we need not even look overseas for better. The Welsh Gender Service has seen a growing shift towards the provision of hormone therapy for trans people in primary care settings, supported through close collaboration with community organisations and GP practices. This has proven to provide a better experience for trans patients and has improved the efficiency of the service from an NHS perspective. The ICTA reportdescribes what this looks like in practice.

Case Study 4 in Chapter 4 reports on the establishment and initial development of regional primary care clinics, spread across Wales, which take responsibility for prescribing and monitoring HRT for trans adults following assessment at the specialist gender clinic. This is the most significant initiative we studied to address lack of integration between an assessing gender service and arrangements for prescribing and monitoring HRT. The key features are as follows. Their effectiveness and efficiency would appear to be of wider relevance to other gender services and NHS primary care commissioners.

The regional clinics were largely staffed by GPs, located within established GP practices and funded by the local NHS. They took responsibility for prescribing hormones, monitoring blood tests and titrating doses immediately following assessment, aiming to pass service users on to their usual practice after around 12 months, on the basis that their doses and prescriptions would by then be stable. This arrangement avoids the costly and damaging difficulties in communication between GICs and primary care practices over blood tests and dosage changes, experienced by many people attending other GICs. It also frees up gender specialists to devote more time to assessments, rather than review appointments for people already on hormones. Local clinicians, however, worked in an integrated way with their specialist colleagues, attending joint training on trans health care, and holding regular joint clinical consultations.

Further advantages emerging from this arrangement include the regional clinics rapidly becoming established as having GPs confident in prescribing under shared care with a GIC, whether based on a full GIC assessment or on the basis of a ‘harm reduction’ bridging prescription. These more knowledgeable GPs can then advise and educate colleagues in their own and neighbouring practices. Above all, both service users and GPs involved in these regional clinics were enthusiastic about how they brought HRT for trans people into the mainstream of primary care. Doctors in the regional clinics helped service users deal with a range of health issues, and hormone therapy came to be experienced as part of primary care, rather than something specialised, difficult, or in any way stigmatised.

The Welsh model is still far from perfect. However, it proves that there is no need for NHS England to keep asking the same tired questions and presenting the same tired answers. Yes, we deserve better than the Levy Review: but more importantly, positive change is both realistic and possible.

Podcast: Who Who Is Wes Streeting and Why Is He Like That?

Last month I returned to the fabulous Red Medicine podcast to talk all things Wes Streeting. I joined the socialist writer Jonas Marvin and host Sam Kelly to discuss the UK Secretary of State for Health and Social Care’s political background, possible motivations, and current challenges.

Red Medicine always offers a great deep dive into health-related topics of the day. Streeting’s alignment with transphobic pseudoscience and conversion proponents means that obviously I had a lot to say about his impact on trans healthcare. However, our conversation was offered a great opportunity to grapple with the wider context of Streeting’s ideology and actions, discussing wider matters such as class, party politics, and trade unionism: highly relevant given current discourse around the proposed strike by resident doctors! I also talk a little about my encounters with Streeting in the 2000s, back when I was a campaigner with the National Union of Students’ LGBT and Women’s Campaigns.

You can listen to Red Medicine through all the major podcast platforms – or through the link below.


You can also hear me talking about the Cass Review on a previous episode of the podcast in June 2024.

Free resources: Perinatal care for trans people

On 8 February 2021, Brighton and Sussex University Hospitals NHS Trust published a series of groundbreaking resources on perinatal care for trans people, written by their Gender Inclusion Midwife team. As of March 2025, the Trust no longer exists, the midwives in question work elsewhere, and the resources page was sadly taken down – a sadly all-too common experience with NHS guidance for working with marginalised peoples.

Given the importance of these materials, for which I was part of a large team of expert reviewers, I am reproducing them on my website today for Trans Day of Visibility 2025, alongside some related resources.

I hope these will be of interest and use to anyone interested in improving perinatal care for trans people, including midwives, nurses, doctors, policymakers, commissioners, advocacy groups, and of course also families and prospective parents.

Professional guidance and protocols by the Gender Inclusion Midwives

Perinatal Care for Trans and Non-Binary People

Gender Inclusive Language in Perinatal Services


Information, forms, and materials for birth parents by the Gender Inclusion Midwives

Support for trans and non-binary people during pregnancy, birth and the postnatal period

Referral to Gender Inclusion Midwives

My language preferences

Pronoun stickers

Poster: Gender Inclusive Perinatal Care


Additional materials

It’s been a long four years since the Gender Inclusion Midwives resources were published. Here, therefore, are a few additional materials that may be of help to people working in this area.

National Maternity Survey data on trans birth parents
Since 2021 the Care Quality Commission has collected data on gender modality as part of its annual National Maternity Survey. The most recent findings indicate a significant rise in the number of men and non-binary people giving birth since 2021, with 1.58% of 2024 respondents indicating a gender that differs from the sex they were assigned at birth. This shows that hundreds of trans people are giving birth in England every year. See: Open data > 2024 Maternity survey National tables > page g9.

Inclusive language statement from the Royal College of Midwives
2022 statement affirming both that a majority of RCM members and service users are women, and that diverse gender identities should be recognised in midwifery.

Improving Trans and Non-Binary Experiences of Maternity Services (ITEMS)
2022 report published by the LGBT Foundation, looking at the findings of an English study on the experiences of 121 trans people who conceived and gave birth. It found that many trans birth parents do not feel safe sharing their identity in perinatal services, with a large proportion not feeling comfortable to access any support at all from an NHS or private midwife.

Trans Pregnancy Project website
I reviewed the Gender Inclusion Midwives resources as part of my work on the Trans Pregnancy Project, which was an international study of trans people’s experiences of pregnancy and childbirth. This year we launched a new website. This includes links to all our peer-reviewed publications, on topics including conception, pregnancy loss, midwifery, gender and embodiment, domestic violence, racialisation, and media representation.

Caring for Everyone: Effective and Inclusive Communication in Perinatal Care
One of the key recommendations of the Gender Inclusion Midwives’ guidance on Gender Inclusive Language in Perinatal Service is the adoption of “additive” language. This approach acknowledges male and non-binary birth parents alongside mothers, rather than simply replacing woman-centred language with a gender-neutral approach. This 2025 academic article by Matthew Cull, Jules Holroyd, and Fiona Woollard provides advice on a “pluralist” approach to language, which builds upon the additive model by offering a more contextual approach. It includes clear examples of what best practice can look like.

Image of poster on gender inclusive perinatal care. For version accessible to text reader, see download link above titled Poster: Gender Inclusive Perinatal Care.

Amplify trans youth

This morning I logged into instagram and watched, transfixed in amazement and worry, as a young person scaled the walls of the Department for Education.

The aspiring spiderman is part of the activist group Trans Kids Deserve Better. At the time of writing they are staging a multi-day protest at the Department for Education building in London, for the right to a safe and inclusive education.

Watching the video, I fear for Squirrel, the anonymous activist who is genuinely risking their life to stop government employees from taking the group’s banner. It’s very apparent that Squirrel is a skilled climber who knows what they are doing – equally, one wrong move could result in a deadly drop to the concrete pavement. This is not safe.

But of course, the entire reason this protest is happening is because young trans people are not safe.

Trans Kids Deserve Better launched their campaign for youth autonomy, safety, respect, and inclusion in July, from a dramatically high ledge of an NHS England building. In an interview with Jess O’Thompson for Trans Writes, the emergency doctor and children’s TV presenter Dr Ronx Ikharia argued that “our young people deserve better than suffering, and shouldn’t be scaling walls”. But they added that for this to happen, trans kids must be “believed, supported, affirmed, and loved”.

And this is the crux of the issue. Under the Conservative and Labour governments, we have seen a policy environment in which teachers, doctors, therapists and parents are actively discouraged or prevented from believing, supporting, affirming, or loving young trans people. Instead, families face prison sentences for supporting young people’s continued access to medication, NHS England is expanding the provision of state-funded conversion clinics, and a growing number of schools are refusing to allow even the discussion of trans experiences.

Trans kids are not safe because they have been entirely failed by the adult world. They have been failed by politicians, failed by civil servants, failed by the NHS, failed by the voluntary sector, failed by researchers, and in many cases also failed by their doctors, teachers, and parents or carers. This is why the activists from Trans Kids Deserve Better are literally scaling walls in their fight for an actual future.

Looking at the challenges facing young trans people, it can be easy to lose hope. But the actions of Trans Kids Deserve Better show that there is a better way. Doomerism helps nobody. The successes of successive liberation struggles have come about because people have continually dared to believe that a better world is possible, and fight for it. The young people currently sat outside the Department of Education are not bemoaning what they have lost: they are insistently demanding change.

Image from Trans Kids Deserve Better

What can we do? In their conversation with O’Thompson, activists from Trans Kids Deserve Better explained that while trans adults often want to “protect” trans youth, they would rather we “amplify” them: “we don’t need sympathy, we need support”. This is a call to action, with a focus on solidarity, rather than trying to speak for young people or bemoan their situation.

Many adult trans people and allies have complained about the lack of mainstream media coverage for the actions of Trans Kids Deserve Better. But we should not simply wait for the papers or news programmes to start caring. It’s up to us to talk about what’s happening. Today’s queer and trans communities only exist at scale because we made our own media, told our own stories, and forced the mainstream to catch up.

So I encourage everyone who reads this to share the story of what is happening. Share it on social media, share it with friends and family, share it in conversations at work and in bars and in cafes and in parks and at gigs and festivals. A few days ago I was at a pub in Bath, fresh from Pride, still holding a placard that read “Ban Wes Streeting” (copied shamelessly from someone else in Glasgow a couple of weeks prior). Someone asked what Wes Streeting had done, so I told her. She was appalled, but grateful to have learned what is happening, and better informed to act. Information spreads when we spread information.

Trans Kids Deserve Better are also hoping that more people will contribute to their actions. You can sign up as a supporter, stay updated from their Instagram account, or contribute to their fundraiser.

If you, like me, would rather not see young people risking life and limb by climbing public buildings, it is time to fight with them, not “for” them. Together we can build a safer world.

Out now in Scientific American: “The U.K.’s Cass Review Badly Fails Trans Children”

I have co-authored an article with Cal Horton for the science magazine Scientific American. We take a concise look at what the Cass Review is, what it found, why the methods used were troubling, and how it is being used to harm young people.

You can read the article here. I hope it will be helpful as a basic explainer for why trans community groups, academic experts, and clinical specialists are so concerned about the Cass Review.

Screenshot of Scientific American website.

Writing for Scientific American was a really interesting experience. It was of course radically different to publishing in a peer-reviewed journal: we put the piece together in a matter of weeks, and it was not scrutinised by academic experts from our specific field of study. At the same time, there was an extremely rigorous editorial, fact-checking, and copyediting process that also made it very different to publishing in most magazines or newspapers.

I was deeply impressed with the sheer amount of time and care the Sci Am editors put into this piece. On one hand, their contributions ensured the piece is written in accessible language, with an international (and especially US-based) readership in mind. On the other hand, we had extensive discussions to ensure that all points made in the article could be rigorously evidenced, including some very detailed exchanges about the specifics of UK law, and what exactly the Cass Review document does and does not have to say about exponential growth over different periods of time. We had to be able to strongly back up any even slightly contentious point.

It was a challenging experience, but one I felt very held by as an author committed to consciencious research practice. Publishing this piece in Sci Am definitely ensured that it was as good as it could possibly be.

Trans Kids Deserve Better – protest at NHS HQ

Young trans people have been leading an incredible protest at Wellington House, the London headquarters of NHS England. They have been holding space on a ledge of the front facade since London Pride on Saturday 29 June.

The protesters will be coming down today (Tuesday 2 July) and have called for supporters in London to join them at a rally from 4pm.

Photo of a group of people sitting on a ledge of a building, with towering pillars and glass windows behind them. They are holding a large banner which reads "We are not pawns for your politics". They have decorated with the windows of the building with trans flags, placards, and the words "trans kids deserve better".


The action powerfully highlights the repeated failure of UK politicians, the mainstream media, and NHS bodies to truly listen to young trans people about their experiences and needs. This is perhaps most powerfully seen in the Cass Review, which has systematically excluded expertise and evidence from trans people in formulating its recommendations, and in trans healthcare bans implemented for under-18s in England in Scotland. Meanwhile, the Labour party are promising to uphold these bans and implement a range of deeply transphobic policies should they win the election on 4 July.

These concerns are powerfully highlights by the protesters themselves. In Diva, a 17 year old activist explains:

“Decisions are being taken that affect our lives without any trans people in the room, let alone trans young people. Too often trans kids are portrayed as a monolith of confused, depressed teenagers. We are denied choice and robbed of our autonomy. But we should be trusted to make the same decisions about our healthcare that all people are. 

In every other way I am trusted when I tell people what I want to do with my life. But not now. There is so much real anger out there and we hope our actions will encourage others to fight for a voice, and the healthcare and dignity that we are currently denied.”

Another protester explained to Pink News:

“We are staging this protest to remind politicians and voters that we’re real kids, not just political talking points. We may not have a vote, but it is our lives that are at stake. Gender-affirming healthcare is a matter of life and death for us and we hope our actions will bring awareness to this fact and encourage others to fight for the healthcare and dignity we are so shamefully denied.”

As a former youth activist working in this field for almost two years now, I am hugely heartened and inspired by this powerful protest. In the face of institutionalised violence and silencing, young trans people are seizing the narrative. It is up to us adults to listen, learn, and fight alongside them.

My speech on the Cass Review and Scotland’s trans healthcare ban (with footnotes!)

This post shares a video and transcript of my speech at the emergency demonstration in George Square, Glasgow, on 18 April 2024, against the decision from NHS Greater Glasgow and Clyde to ban endocrine treatments for trans people aged under 18. The speech was unplanned and made without notes, so I have made some small corrections in the transcript, plus minor amendments for clarity. I have also added references for some key points. Thank you to @transprotestglasgow for the video.

Readers seeking more detailed evidence and academic critiques may find my previous blog post helpful: What’s wrong with the Cass Review?

TRANSCRIPT

Hi, I’m Ruth Pearce.

I’m a Lecturer in Community Development at the University of Glasgow, and I’m a researcher on trans healthcare.

And I was a trans child.

I want to talk about that for a moment. Because I came out to myself circa 2001, when I was 15, when not many people did that. And it was hard for us. And there was trans community, and there was information, but it was very difficult because we felt very, very alone. I was mostly only able to connect with other trans people my age through the internet, through blogs, and they were mostly Americans. The Brits were there; a lot of us connected later as we grew older. But we were so isolated.

A really important thing to remember, in a moment like this where we are seeing a return to the kind of medical policies that were in place when I was a kid: there are so many more of us, and we are so much more powerful than we have ever been.1 Never forget that strength we have together.

One of the things Hilary Cass says in her report is that the meaning of the word “trans” has changed since 2020.2 She says, and there is no evidence for this, that “trans” in 2020 meant something quite rigid and specific, and only now in 2024 it’s become an umbrella term for lots of identities. Tell that to me coming out as a trans teenager in 2001!

So here’s the thing. We’ve always been here, and we are more powerful now, but we are seeing this backlash. That’s been a long time coming and transphobia changes its face over time. One of the things I wanted to do to deal with my loneliness and the experiences I had was that I wanted to become an activist. And when I started doing activism, when I got into meetings with people in government, and with the Equality and Human Rights Commission, they said “there’s no evidence” for the discrimination we faced. So I was like, “fine: let’s see what evidence I can find”.

So I did a PhD in trans healthcare.3 And I found what you often find when you do research; you often find things you don’t expect. So I did find some things I expected to find. About waiting lists and how hard they are. About how hard appointments can be when you’re meeting with sexist and transphobic clinicians who are asking you, as a young person, how you masturbate and who you’re attracted to. But what I didn’t expect was the sheer level of pain from the waiting. And I talk about that in my work. And the anticipation, where we are anticipating all the time. When is it going to happen? When are we going to get to live our lives? And that happens on every level of our lives.

I was also shocked by the level, and detail, and complexity of the ignorance of healthcare practitioners. It ranges: it’s not just that they all hate us, right? It’s that some people are trying to control us, some people want to help but don’t understand how, and some people don’t want to know. There’s different kinds of ignorance.4

So I published my work, and other people have followed. Other people were there before me of course, because “trans” was not new, and trans research wasn’t new either. There is now a lot of published research on what it is like to go through a gender clinic, and what it is like for a young person to go through a gender clinic. There’s people like Cal Horton5 and Natacha Kennedy6 who are writing on this, and Harvey Humphrey7 who works here in Glasgow. There’s a lot of people doing work on this.

We are saying, time and time again, “we need services that meet our needs”. For some people, that is access to puberty blockers, and that is access to hormones. For other people, that is access to counselling, and therapy, and community support. What we call “trans-affirmative” or “gender-affirmative” care is flexibility, meeting a person where they are at, and based on what they want to do with their lives.8 You don’t have to change your body – but you can.

It’s our body, it’s our right: we can do what we want with our own bodies.

This is what is disgusting about the decision by NHS Greater Glasgow and Clyde. They have not addressed the years and years of mistreatment and abuse in their child and adolescent clinic at Sandyford. It is not a great place that we are trying to save. It is a clinic that has repeatedly refused to treat young people, and made people hold on for care. It has helped a handful of people. Dozens of people – only dozens – have accessed treatment in the last few years.9 Now they are proposing to stop doing the very little they are doing to support young trans people.

People who get a referral to a child and adolescent gender clinic are not necessarily seeking access to counselling and therapy, because you can get that elsewhere.10 They are not seeking access to community, because you will find no community at Sandyford. They are most likely seeking access to endocrine treatments: puberty blockers and hormone therapy. And that’s what they are going to stop doing.

Sandyford say they are still accepting new referrals. But what is the point of a gender clinic that does not offer people medical treatment?

NHS Greater Glasgow and Clyde have based their decision on the final report of the Cass Review. Let’s talk a bit about the Cass Review.

I’m an academic researcher. If the Cass Review was submitted by an undergraduate student, the first thing I would say is: “That’s nearly 400 pages long! No-one’s going to have time to mark that”.11 And you’ll notice that all the people in the media, all the Labour politicians, all the Tory politicians, all the people saying we should immediately implement the findings of the report: none of them read nearly 400 pages in one day. Neither did the journalists at the BBC, the Telegraph, the Times, the Daily Mail, the Observer, the Independent. We expect better! And now the Scottish media: it’s all over the Scotsman, the National, the Herald. None of them have bothered to read the report, or think about it critically.

So here’s a bit of information about the Cass Review. The Cass Review was undertaken by a group of people who, from the very start, excluded trans people from oversight of the project. That was in their terms of reference.12 They didn’t want people who had experienced services having a formal part in the report. They excluded healthcare experts. If you were someone who had worked in a gender clinic you were excluded from being part of that.13 You know, I have lots of disagreements with many people who work in gender clinics, but you would have thought they might get a say.

You can see that ignorance, that intentional ignorance, playing out in the final report of the Cass Review. You can see, if you read the Cass report, that they looked at over 100 studies, most of which show that puberty blockers and hormone therapy can help young trans people. And they just ignored them.14 Intentionally. They say that the majority were not “high quality evidence”.15

What else is not high-quality evidence in healthcare? Paracetamol for back pain.16 There is no high quality evidence for that, in the terms of the Cass Review. Anti-psychotics.17 ADHD medication.18 All these medications that are in regular use. You know what else? Puberty blockers for young people with precocious puberty – if they’re cis.19 That is direct discrimination. 20

The thing is, that’s the Cass Review being serious. Let’s think about when it gets weird.

There’s a graph in there, where they show referrals to a gender clinic (the Gender Identity and Development Service in England) rising year on year, with “an exponential rise in 2014”. But they cut the graph off at 2017. But if you look at 2017-2020 the referral rate flattens off. It’s deliberate removal of evidence.21

We know why this is happening. Experts – medical experts, and experts by experience have been cut out of the Cass Review process. If you are trans, that’s you. You are an expert by experience. You know what it’s like. We have been cut out the process!

And the NHS have done that here in Scotland. There was no consultation on the ban that’s come in.

Who did they consult? We know there are people who are proponents of conversion therapy who were on the Cass Review team.22 That is what they are proposing.

They are proposing conversion therapy. Not just for trans kids, because they want to deal with all gender-questioning and non-conforming kids. This is going to be conversion therapy for queer kids. Little boys who want to wear a dress, they might not be trans, but they deserve to have the space to explore. That is not going to be what happens in clinics where people are referred which are being informed by conversion therapists.23

So consequently you have other weird stuff in the Cass Review. They’re dismissing all the evidence about why puberty blockers and hormones can benefit people within particular contexts, but they’re relying on other evidence for their recommendations. Let me give you one citation. “Thoughts on Things and Stuff, 2023”. That is a citation from the Cass Review: Thoughts on Things and Stuff.24

What is “Thoughts on Things and Stuff”? It’s a right-wing Youtube channel run by anti-trans bigots,25 featuring contributors such as “Gays Against Groomers”.26 This is the level of evidence that is informing NHS Greater Glasgow and Clyde.

And I’ll tell you what else is in the Cass report. They say that little girls are likely biologically inclined to play with dolls. It’s right in there, in the Cass report.27 And little boys are probably biologically inclined to play with trucks. Why is this? It’s not just an anti-trans agenda. It’s an anti-feminist agenda. Its an anti-woman agenda.

Why is this happening? It’s happening because trans people are an easy target.

If you want to stop young people accessing contraception as teenagers, you remove trans people’s right to consent to care as young people. If you want to prevent young people – teenage girls – from having abortions, and you’re failing time and time again in the courts, you instead target puberty blockers, because that way you can set a precedent for preventing people from being able to make decisions as young people. You are undermining the idea that young people might have the capacity to consent to care and make an informed decision about their own bodies.28

So I will end on this. I’m a woman, I’m a trans person, and I think it’s really important we think about allies. I had the parent of a trans child contact me and say, “thank you for being an ally”. I want to think her for being an ally. The thing about allies is, we talk a lot about an “ally” being someone who supports somebody else. But no: allies are people who stand by each other and work together.

That’s why we need a trans feminist movement. A trans feminist movements gives people autonomy over their own bodies, space to make their own decisions, and enables people to stand together when we are all at risk.

So I’ll leave you with a chant I want to hear more of at protests:

“Trans rights, women’s rights: one struggle, one fight”.

FOOTNOTES

  1. My statement here is intended to highlight that more people are out as trans than ever before. Contrary to narratives of “social contagion”, there have always been people with gender diverse or sex nonconforming experiences. What has changed is that there is greater access to information and community, which makes it easier for people to come out. ↩︎
  2. “During the lifetime of the Review, the term trans has moved from being a quite narrow definition to being applied as an umbrella term to a broader spectrum of gender diversity. This clearly has implications for conceptualisations of detransition” (Cass et al., 2024, p.187). This claim is demonstrably false, as “trans” (and before that, “transgender”) has been used as an umbrella term for decades. This is shown in my own previous work as well as writing dating back to at least the 1980s by individuals such as Leslie Feinberg. ↩︎
  3. https://wrap.warwick.ac.uk/88285/ ↩︎
  4. For an excellent, more recent and more detailed analysis on this topic in the context of trans youth healthcare, see Magdalena Mikulak’s (2021) article “For whom is ignorance bliss? Ignorance, its functions and transformative potential in trans health“. ↩︎
  5. https://growinguptransgender.com/evidence/ ↩︎
  6. https://www.gold.ac.uk/educational-studies/staff/kennedy-natasha/ ↩︎
  7. https://www.gla.ac.uk/schools/socialpolitical/staff/harveyhumphrey/ ↩︎
  8. “Our stance, as gender-affirming practitioners, is that children should be helped to live as they are most comfortable. For a gender-nonconforming child, determining what is most comfortable is often a fluid process, and can modify over time. Therefore, in a gender affirmative model, gender identity and expression are enabled to unfold over time, as a child matures, acknowledging and allowing for fluidity and change” (Hidalgo et al., 2013). ↩︎
  9. “Since 2018, around 1.77% of young people who are referred to the gender care services at Sandyford have gone on to be prescribed puberty blockers”: https://www.thenational.scot/news/24262271.many-young-people-scotland-given-puberty-blockers/. ↩︎
  10. Although in practice, trans people are often also turned away from mental health services due to “trans broken arm syndrome“. ↩︎
  11. In my original speech, I inaccurately stated that the report was “500 pages long”. However, my point about requiring time to carefully consider its contents remains. ↩︎
  12. “The original published Terms of Reference (ToR) for the Cass Review’s assurance group explicitly excluded trans expertise, stating that it “deliberately does not contain subject matter experts or people with lived experience of gender services” [Report 1, version 1]. The current (updated) assurance group ToR is worded less clearly, yet still conveys exclusion of those with expertise or lived experience, as such individuals would naturally be expected to have an interest in the outcome of the review” (Horton, 2024: p.7) ↩︎
  13. One former gender clinician was involved in the research process: Tilly Langton, formely of England’s Gender Identity Development Service (GIDS). Langton’s recent activities include promoting conversion therapy materials in training for NHS psychiatrists and lobbying Kemi Badenoch about the UK government’s conversion therapy ban, alongside proponents of conversion practices. ↩︎
  14. Hilary Cass has contested this claim in reporting for the BBC. Her argument is that of the 103 studies analysed for the review, 60% were included in the synthesis of evidence. However, my argument here is specifically that the findings of these papers were broadly ignored in the writing of the report’s recommendations, while less robust material was instead prioritised. As Simon Whitten argues, “The majority of moderate certainty studies were included in the results section but then arbitrarily ignored in the conclusion entirely”. ↩︎
  15. I have removed a statement I made about randomised control trials from the transcript here as my point was unclear and therefore potentially misleading (as can happen when you do an unplanned speech on a complex topic!) Unlike the Cass Review team, I am keen to correct my errors. See the links in the above footnotes above for more detailed information on inclusion/exclusion criteria for the Cass Review. ↩︎
  16. See e.g. https://www.nps.org.au/news/is-paracetamol-effective-for-low-back-pain. ↩︎
  17. The landscape of evidence anti-psychotics is a complex one. There is “high-quality” evidence that anti-psychotic drugs work better than placebos in addressing various conditions, but the evidence for use of multiple drugs, reducing or increasing doses at particular junctures in treatment, or taking one drug rather than another in treating specific conditions is often of a similar (or lower) quality than the evidence for benefits of endocrine interventions assessed by the Cass Review (see e.g. https://www.sciencedirect.com/science/article/pii/S0890856716319992). ↩︎
  18. Specifically in the long-term, see e.g.: https://www.nationalelfservice.net/mental-health/adhd/adhd-medications-effective-safe/. ↩︎
  19. https://onlinelibrary.wiley.com/doi/10.1111/cen.14410 ↩︎
  20. At this point, somebody stuck their hand up in the audience. I responded: “Someone stuck their hand up and might give me a footnote on that! I totally approve of that. I might invite you up later because I like evidence and I’m obsessed with it. [person indicates they were just waving to their friend, crowd laughs] Oh that’s grand! There we go, we haven’t even had a footnote.” Well, here is the footnote. ↩︎
  21. p.24 of the Cass Review final report. The rationale for this within the report is that the figure is adapted from a 2018 paper published in Archives of Sexual Behaviour. However, as Trans Actual observe: “The number of referrals to GIDS is known until 2020/21 […] the last 3 years for which data is available, shows that the number of referrals has recently plateaued. Such data is inconvenient for a narrative that relies on an inexplicable explosion in need[.]” ↩︎
  22. https://transsafety.network/posts/gender-exploratory-nhs-training/ ↩︎
  23. A historical example of treatment that “tries to make the child comfortable with the sex he or she was born with” within a gender clinic context can be found here: https://www.npr.org/2008/05/07/90247842/two-families-grapple-with-sons-gender-preferences. ↩︎
  24. p.70, used to evidence the activities of GIDS’ research team at a WPATH conference. They could have instead cited the conference website. ↩︎
  25. A good summary of the channel can be found in this piece by What The Trans: “When citing a recording from the WPATH 2016 conference, Cass uses a YouTube channel called Thoughts on Things and Stuff. This appears to be the associated channel of a now-defunct blog largely focussed on criticising the Mormon Church. Why this was relevant to Cass is unclear, although titles of recent uploads at the time of the WPATH video include “Dr. Stephen Levine: 13 Untruths Behind Gender Affirmative Therapies for Kids” (Levine is an advisor to Genspect) and “Gays Against Groomers: stop the indoctrination and medicalization of children. 2023 Florida testimony.”, which perhaps provides a clue to how Hilary Cass ended up citing a channel with only 22.4K subscribers. It thus seems that, in addition to being advised by and networked with a variety of prominent anti-trans figures and organisations, Hilary Cass appears to be getting her professional news from homophobic and transphobic YouTube channels.”  ↩︎
  26. Anti-gay campaigners have long attempted to position LGBTIQ+ people as a danger to children. In recent years this tactic has seen a resurgence, through positioning trans and queer campaigners as “groomers”. GLAAD have described Gays Against Groomers as a group who intentionally use “ambiguous messaging about characterizing LGBTQ+ people as pedophiles falsely and maliciously with the absolutely clear intent of driving fear.” ↩︎
  27. pp.100-101 ↩︎
  28. https://transsafety.network/posts/bell-v-tavistock/ ↩︎

Let’s respond to the NHS consultation together!

A couple of days ago I joined Katy Montgomerie’s livestream to work through the current NHS England consultation on child and adolescent gender services. We discussed the background to the consultation, what the questions mean, and what some of the major issues are.

You can take part in the consultation here. It is open until 4th December 2022. Filling it in is a bit of an intense experience, but if you fancy some friendly company and catty cameos, I hope our video will help.

NHS England proposals put young people in danger

NHS England logo

Three weeks ago, I wrote to the NHS England Gender Programme Board (of which I am a former “patient public voice” member) to raise urgent concerns about their consultation on a new interim service specification for children and adolescents.

The proposed service specification is deeply transphobic on numerous levels – from the dearth of relevant treatment pathways, to the assertion that being trans is likely a “phase”.

It is also probable that if implemented, this service specification will impact other young people more widely – especially girls and LGBTIQ+ youth – by undermining principles of autonomy and respect.

You can read more about the service specification here.

The proposals have been condemned by UK and international experts including Dr Natacha Kennedy, Cal Horton, and the Australian Professional Association for Transgender Health. Their well-evidenced critiques are well worth a read, especially if you might consider participating in the consultation. Edit 26/11: the proposals have now also been condemned in a strongly-worded and well-evidenced statement from world professional bodies WPATH, ASIAPATH, EPATH, PATHA, and USPATH.

The consultation is open to anyone. If you have the time and energy, there is a guide to participating in the consultation here, prepared jointly by Gendered Intelligence, Stonewall, Mermaids, and the Trans Learning Partnership. If you are a community member, a healthcare practitioner, a researcher, or work with a relevant charity, it would be particularly useful for NHS England to hear from you.

Other things you could do to oppose the proposals include: organising a demonstration, raising awareness of this issue on social media, and/or writing to your MP or trade union and asking them to place pressure on NHS England to reconsider.

To date, I have not received a reply from NHS England. Given the danger the proposed service specification poses to the safety of young people, I have now decided to make my letter to them public.

~

Dear all,

I am emailing to share my great alarm at the proposed service specifications for child and adolescent gender dysphoria services. It is my expert opinion that, if implemented, these proposals will cause great harm to young people. Moreover, in opening such poorly designed and unevidenced specifications to consultation and media commentary, NHS England has already caused harm.

The fact that this consultation is happening at all represents an enormous failure on the part of every professional involved.

I stepped down from the Gender Programme Board earlier this month due to clashes with my teaching schedule. However, given the severity of this situation, I would be remiss in my ethical duties if I did not also email you directly to share my concerns.

My three main areas of concern are:

  1. Social transition should not be subject to medical oversight. This would represent a gross abuse of power on the part of commissioners and practitioners. Choosing to wear different clothes, and possibly use a different name and/or pronouns – is a personal, non-medical decision related to a person exploring their identity and/or coming out. Preventing a young person from choosing a social transition amounts to an attempted conversion practice.

  2. Punishing young people and their families by subjecting them to investigation if they access private services will not help them access healthcare. Young trans people who access private healthcare in the UK or abroad generally due so due to the severity of NHS failures.  It will increase the likelihood of young people hiding the fact they are accessing external treatment from NHS clinicians, and of people turning to black-market hormone providers rather than private doctors. I am not sure that members of the Gender Programme Board are fully aware of how prevalent and dangerous the home-made substances already in circulation can be.

  3. Requiring that young people become research subjects as a condition of accessing treatment is completely unethical. This is a well-established principle in the trans health literature. There is no way in which you can truly obtain informed consent for research participation from individuals who will be denied healthcare if they refuse to participate. I fully support the expansion of NHS-funded research into trans healthcare, but participants must not be recruited through coercion.

I will end by inviting all recipients of this email to reflect on what they do not experience, and what they do not know.

Most members of the Gender Programme Board have not experienced gender incongruence or gender dysphoria.

Most members of the Gender Programme Board are not members of a trans community. It is likely therefore that you – even if you are a clinician – have never found yourself in a position where you are confronted with the true impact of NHS failings on young trans people who rely on community support. You do not know what it is like to be trying to look after many extremely damaged members of your community dealing with complex trauma and self-harm from people who have been repeatedly abused by NHS clinicians and processes. We, in the community, are the ones left picking up the pieces of your failings, finding ourselves on constant suicide watch and scrabbling to keep people alive. Invitations onto bodies such as the Gender Programme Board, where we are expected to be polite while fighting for scraps – only to be ignored – do not right these overwhelming wrongs.

It is now on you to rebuild trust.

Sincerely,

Ruth

Cass Review GRA study an appalling breach of research ethics

Logo of the Cass Review

I was dismayed to read that the UK Government are amending the Gender Recognition Act. Specifically, they are removing the offence under section 22(1) of the Gender Recognition Act 2004 for the disclosure of protected information, to enable this disclosure where it is “necessary for the purposes of facilitating, assisting or undertaking relevant research”.

This amendment enables NHS England to obtain trans people’s confidential information about their medical treatment for the purpose of research into child and adolescent gender services by the Cass Review. Specifically, it enables the acquisition of information (a) that could contain personal identifying details, (b) without that person’s consent, and (c) for individuals who obtained specific legal protections with the reasonable belief that these would remain in place. There has been no community consultation ahead of this move.

As a social researcher and expert in ethical methodologies, I believe that any research undertaken under these circumstances would represent an enormous breach of the basic principles of research ethics. Moreover, it will could significantly undermine the already extremely low existing low level of trust between trans community members, researchers, and medical practitioners.

Finally, the amendment also represents a significant weakening of the Gender Recognition Act’s legal protections for trans people (although for a full and measured analysis, see this post by What The Trans).

I have therefore written to the NHS England’s Gender Identity Programme Board to express my concerns about this development. I also hope that any university or NHS ethical panel overseeing the approval of such research will prevent it from taking place.

You can read some of my published work on ethical research with trans populations here.

You can write to the Cass Review to express your concerns here.

Posted updated 2 July to include new details.