Respond to NHS consultation on new gender hubs for children

25 November 2022

NHS England is holding a consultation on major changes to its gender dysphoria services for children and young people. It is consulting on its proposed Interim Service Specification for the service, which will lead to the establishment of two new gender hubs in England.

This is a significant opportunity to protect young people and children from damaging transgender interventions.

Please respond using the guide below. You can also read our full response. The closing date is Sunday 4 December.

We recommend responding to questions 3-7, once you have filled in questions 1 and 2 indicating who you are and, if necessary, which organisation you represent.

3. To what extent do you agree with the four substantive changes to the service specification explained above?

A. Composition of the clinical team

We suggest answering Disagree

We disagree with this proposal overall, because despite there being some improvements in the Interim Service Specification, some of the key problems already found in the GIDS are set to continue.

Key points to make

Only psychosocial and psychological support and intervention should be allowed

Psychosocial and psychological support and intervention is proposed to be the primary intervention for children and young people. In reality this should be the only suitable intervention for all children and young people referred. The reason is that affirmative treatment is harmful for children and teenagers. The evidence for its harmfulness is set out in the expert witness cited in our legal case supporting Nigel and Sally Rowe, which is referred to in our full response.

Affirmative treatment is harmful – Dr. Paul McHugh

Puberty blockers are harmful – Professor Quentin Van Meter

Multidisciplinary teams

This is good in principle, but there are serious problems with the details.

Whilst we welcome the proposal to have multidisciplinary teams in principle, we note that the new specification includes ‘gender dysphoria specialists’, with ‘experts in mental health’ added at the end after emphasising ‘experts in paediatric medicine, autism, neurodisability’. This signals a downgrading of the importance of mainstream psychotherapists and psychologists, as well as complete removal of social workers from these teams. This is a serious problem that needs to be addressed.

We do not think that paediatric endocrinologists should be part of these Multi-Disciplinary Teams, as the only reason for their inclusion is to facilitate administration of puberty blockers and cross-sex hormones. These are experimental treatments that are contrary to medicine.

Childhood transition should not be allowed under any circumstances

The Interim Service Specification clearly allows pre-pubertal children to transition and assumes uncritically that they have adopted this mindset all by themselves (page 14).

This contradicts the scientific evidence against affirmative treatment. The ‘watchful waiting’ alternative is not good enough. It does not have the goal of resolving gender incongruence, rather it allows for waiting until the child has made his or her own mind up about whether or not to change gender. Therefore, the proposed new ‘watchful waiting’ paradigm still allows the child to make all decisions, ignoring parental authority and rights to bring up children as members of their biological sexes.

  • We suggest you say that you are opposed to affirmative treatment or a ‘watchful waiting’ approach.
  • We also suggest that you say that children and young people should be encouraged in all circumstances to live in line with their biological reality and given all appropriate support to address the real cause(s) of their gender dysphoria.

Who will staff the new gender hubs?

There will have to be new clinical staff, including mental health professionals, in these new Multi-Disciplinary Teams. The fact that a significant minority of therapists resigned from the GIDS not long ago leads to the question as to whether they would now be treated as eligible for the new posts. It is clear that these therapists believed in talking therapy not physical procedures such as puberty blockers accompanying gender transition.

The key problem here is that NHS England remains a signatory of the professional ban on ‘LGBT conversion therapy’, the Memorandum of Understanding on Conversion Therapy. This has caused the bias in favour of affirmative therapy at the GIDS.

Dr Marcus Evans, one of the GIDS whistle-blowers (a qualified therapist and mental health nurse) has argued that the MOU has prevented clinicians’ ability to provide adequate therapy for children referred to the GIDS.

  • We suggest you say that NHS England should withdraw from the Memorandum of Understanding on Conversion Therapy so that clinicians to not feel obligated to affirm a child’s self-defined gender identity. They should also be willing to re-employ those therapists who resigned and/or whistle-blew about what was happening in GIDS.

Concerns about anorexia among gender confused children ignored by consultation

The consultation document is selective in addressing possible underlying problems among children with gender confusion. For example, children known to be on the autistic spectrum are overrepresented among referrals. However, it is a problem that the significance of anorexia among children referred is never mentioned in the consultation. It is however discussed at length by Marcus Evans and Susan Evans in their book on gender dysphoria.

Susan Evans and Marcus Evans, ‘Early Development in the context of the family’, in Susan Evans and Marcus Evans, Gender Dysphoria: A Therapeutic Model for Working with Children, Adolescents and Young Adults. Bicester: Phoenix Publishing House, 2021.

  • We suggest you say that the Interim Service Specification needs to be changed so that the reference to ‘experts in mental health’ once again specifies psychiatrists, psychotherapists and family therapists as members of the clinical teams.

Social workers should be reincluded in Multi-Disciplinary clinical teams

The proposed new specifications exclude social workers completely from the multidisciplinary teams. No evidence is provided to justify their exclusion. As the historical evidence suggests, many children referred to GIDS had emotional and behavioural problems. Therefore, social workers should be re-included in the new multidisciplinary teams.

For therapists and psychiatrists, indeed all medical and mental health professionals, to be free to work to the highest standard in such teams, NHS England must leave the Memorandum of Understanding on Conversion Therapy Coalition, and the Department of Health must withdraw the Memorandum of Understanding on Conversion Therapy.

  • We suggest you say that social workers should be included in the multidisciplinary team and that NHS England must withdraw from the MOU on Conversion Therapy.
B. Clinical leadership

(Agree / Partially Agree / Neither Agree nor Disagree / Partially Disagree / Disagree; comments)

We disagree with the proposal that the new lead should be a medical doctor, as medical conditions are very rarely the underlying issues involved in gender dysphoria. It is highly significant that the Cass Review has not shown any medical problems underlying referrals.

We would like to see leadership rotated between members of the different professions represented. However, for this to work well, NHS England would have to leave the MOU Coalition, as this has clearly been responsible for undermining clinicians’ ability to treat gender dysphoria in children and teenagers.

  • We suggest you say that the leadership of the teams should be rotated between members of the different professions represented.
C. Collaboration with referrers and local services

(Agree / Partially Agree / Neither Agree nor Disagree / Partially Disagree / Disagree; comments)

We agree in principle with this. However, see our response to ‘D. Referral sources’ in the next question below. We disagree with narrowing the referral base to only GPs and NHS staff, given that this excludes psychotherapists and other mental health professionals from outside the NHS. This restricts the range of competent referrers without justification. This amounts to a closed shop for mental health professionals who are members of organisations that are in the MOU Coalition.

D. Referral sources

(Agree / Partially Agree / Neither Agree nor Disagree / Partially Disagree / Disagree; comments)

Unjustified exclusion of private practice psychotherapists and counsellors

This draft Interim Service Specification does not allow referrals from psychotherapists and counsellors outside the NHS. In effect this creates not only a monopoly but a closed shop of mental health professionals entirely dependent on the state, and subservient to the MOU Coalition. This almost guarantees that professionals and clients’ freedom to discuss the problems involved in gender confusion will be restricted, which would be an unjustifiable restriction on free speech in the workplace.

  • We suggest you say that referrals should be allowed from psychotherapists and counsellors outside the NHS.
  • We suggest you say that a requirement of making a referral should be that the referrer knows the patient well and has become familiar with them over a minimum of six month with repeated contact.
  • We agree that referrals from non-medical sources such as schools and voluntary groups should not be allowed.

4. To what extent do you agree that the interim service specification provides sufficient clarity about approaches towards social transition?

(Agree / Partially Agree / Neither Agree nor Disagree / Partially Disagree / Disagree; comments)

Contrary to what the consultation says, it is incorrect to assume that ‘social transitioning’ is ‘necessary for the alleviation of … distress’. To assume this is to cave into emotional manipulation. It is also incorrect to say that it can be necessary to prevent ‘significant impairment in social functioning’. In reality social transitioning it itself both a sign of and instance of significant impairment in social functioning as a member of one’s actual sex.

It makes little sense to state that a ‘young person’ (whose age is not delimited) can ‘fully comprehend the implications of affirming a social transition.’

The recent judicial review of the GIDS only considered whether teenagers could comprehend the effects of physical gender reassignment. The question of whether teenagers can fully comprehend the implications of social transition has never seriously been posed by clinicians or publicly debated. The reason for this is evidently that all mental health professional bodies have signed the MOU on Conversion Therapy, which has proven to have a chilling effect on freedom of speech in the mental health profession.

  • We suggest you say that you disagree with the view that social transition is an appropriate treatment for children suffering from gender dysphoria.
  • Social transition makes it much more likely that a child’s gender confusion will persist into adulthood.
  • The service should encourage social detransition which will make it much less likely that gender confusion will persist into adulthood.

To what extent do you agree with the approach to the management of patients accessing prescriptions from un-regulated sources?

(Agree / Partially Agree / Neither Agree nor Disagree / Partially Disagree / Disagree; comments)

This approach is unethical, as it ensures that the service washes its hands of all legal and clinical responsibility for minors who access dangerous drugs. It is a cynical approach that shows NHS England has given up on any intention to get to know teenage patients and their families, to try to steer them to live in harmony with their biological sexes.

If this were the approach taken towards teenagers taking classified illegal drugs, there would be public outrage and calls for a public inquiry.

  • We suggest you say that the NHS should not avoid responsibility for caring for people who have taken un-regulated prescriptions.

Are there any other changes or additions to the interim service specification that should be considered in order to support Phase 1 services to effectively deliver this service?

We are pleased that use of puberty blocking drugs is proposed to be limited to the context of a research proposal, but we believe that any prescribing of puberty blockers to children is unethical.

  • We suggest you say that we should not be experimenting on children by prescribing them with puberty blockers.
  • It is already known that almost all children who use puberty blockers go on to progress with more damaging gender transition treatments, whereas those that do not use puberty blockers are much more likely to see their gender confusion resolve at the onset of puberty.

To what extent do you agree that the Equality and Health Inequalities Impact Assessment reflects the potential impact on health inequalities which might arise as a result of the proposed changes?

We suggest that you skip this question.

Our full response will be available shortly. The closing date is Sunday 4 December.

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