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.

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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