The role of the GP in transgender care
RCGP position statement, April 2024 update.
October 2024
In 2019, RCGP Council approved a position on transgender care which was published on our website. In April this year, following the publication of the Independent Review of gender identity services for children and young people in England led by Hilary Cass, the College felt it was necessary to rapidly update our position statement. Although due to formatting changes, our revised statement appeared quite different to the original on first view, the updated statement draws heavily on the 2019 position. The aim of this update was not to change the College's position and overall, we believe the updated statement remained in line with the policy position agreed by Council in 2019.
We have received feedback and comments from several organisations and individual GPs following publication of our revised statement in April 2024. After carefully reviewing and considering the feedback, we have added two clarification sections highlighted in our statement below, together with some minor edits to relevant sections of the statement itself to reflect our clarification points. These remain in line with our previously approved Council statement.
We know that the care of transgender and gender-questioning people is complex. We acknowledge that we need to recognise the experiences of our transgender patients as a result of the changes occurring in and limited capacity of our health system. We recognise the deep sense of hurt and frustration that many of our transgender patients are feeling, and the College remains strongly committed to the improvement of services for patients with gender incongruence. We continue to call for significant expansion in resources and dedicated services to ensure timely access to high-quality care. We are hopeful that, with the right investment and action, the establishment of regional gender incongruence clinics across England will lead to a positive shift in waiting lists and improved care and health outcomes.
Executive summary
The role of the GP
GPs are expert generalists; the provision of detailed advice about gender identity issues and associated treatments does not fall within the remit of a GP’s education and training. The RCGP curriculum does however include the need to provide ‘high-quality, holistic and comprehensive care to…transgender people’. The RCGP eLearning site has a course on transgender care, which is currently being updated in light of the Cass review. GPs should be aware that a patient may find the process of approaching a healthcare professional to discuss their gender identity to be difficult or distressing.
The RCGP considers that the role of the GP includes the following:
- To provide a holistic approach, contextualising a person’s presentation of gender incongruence with other conditions and within their broader environment.
- To provide appropriate primary care related to gender-related distress or gender incongruence. This may include the use of non-oestrogen hormonal contraception to manage distressing periods in those who are transitioning from female to male.
- To provide appropriate signposting to patients presenting with gender incongruence alongside other social or medical issues. This may include referral to mental health services or engaging with social care, safeguarding, social prescriber or sexual health colleagues.
- To ensure that all patients can express their preferences for how they wish to be named and referred to and that these are respected.
- To promptly refer, where appropriate, to a Gender Identity Clinic (GIC), or to the appropriate secondary care service if the patient is aged under 18.
- To liaise and work with GICs in the same way as with any other specialist. This includes consideration of prescribing under a shared care agreement (SCA). It is important that SCAs are agreed upon by all parties involved, with consent from all parties, given on a willing and informed basis, ensuring the appropriate levels of resource, competence and expertise are established, as informed by the patient’s level of medical risk. NHS bodies need to ensure that local collaborative care arrangements and locally commissioned services are adequately funded to support the ongoing care and treatment of patients e.g. including integrated services that meet the mental and physical needs of the patient. When responsibility for ongoing medical monitoring and prescribing is assumed by a GP, the limitations of this need to be recognised and mitigated.
- To recognise that the family members of a patient experiencing gender incongruence also face significant challenges and refer these family members to further support services where appropriate.
The RCGP recognises that some GPs have particular expertise, or an extended role, in the area of transgender care and supports them to act in their patient’s best interests, within the limits of their competence. For the majority of GPs, without this expertise or extended role, the RCGP considers that the role of the GP does not include the following:
- Prescribing bridging prescriptions for those on the waiting list for a GIC.
- Prescribing puberty blockers for a patient aged under 18, even on a shared care basis, given the concerns about the evidence base in this area as well as the specialist expertise required to monitor dosage and side effects. The Cass review notes that ‘the Review has already advised that because puberty blockers only have clearly defined benefits in quite narrow circumstances, and because of the potential risks to neurocognitive development, psychosexual development and longer-term bone health, they should only be offered under a research protocol. This has been taken forward by NHS England (NHSE) and the National Institute for Health and Care Research (NIHR)’ and that ‘if an individual were to have taken puberty blockers outside the study, their eligibility may be affected’. This precludes GPs from ever prescribing puberty blockers, excepting any GPs working on clinical trials in this area.
- Prescribing gender-affirming hormones for a patient aged under 18, even on a shared care basis, given the concerns about the evidence base in this area as well as the specialist expertise required to monitor dosage and side effects. The Cass Review advises that ‘NHS England should review the policy on masculinising/feminising hormones. The option to provide masculinising/feminising hormones from age 16 is available, but the Review would recommend extreme caution. There should be a clear clinical rationale for providing hormones at this stage rather than waiting until an individual reaches 18’. We feel that in view of this, prescribing of gender-affirming hormones should generally only be done by specialists.
- Carrying out blood tests on behalf of secondary care or making decisions about how those blood tests affect hormone doses – NHSE advice and primary/secondary care interface documents make it clear that a clinician who wants to request a test should do it themselves.
- Sharing care with the private sector, unless the GP practice has made their own decision to do so and feels that it is safe and resourced.
Policy recommendations
The RCGP calls for the following changes at national level:
- To review the service specification for adult GICs and ensure that the commissioning of gender identity services is sufficient to support the demand for services for patients and advice and good communication to GPs.
- To ensure that services for adults and children and young people (CYP) take a holistic approach, considering neurodiversity, adverse childhood experiences and mental health co-morbidities. We would support innovative models including those which use a ‘hub and spoke’ model to provide care from local clinics run by GPs with Extended Roles (GPwERs) with supervision from a consultant in the field. The RCGP would be open to exploring the creation of a framework for a GPwER in this area.
- To ensure that patients who present to their GPs with gender-related distress have access to appropriate psychological therapy within the community, whilst waiting to be seen in a GIC or as stand-alone therapy for those who do not wish to be referred to a GIC. As noted in the Memorandum of Understanding on Conversion Therapy to which the RCGP is a signatory, while there must be commitment to ending the practice of conversion therapy in the UK, there must also be appropriate support for therapists to provide appropriately informed and ethical practice when working with a client who wishes to explore, experiences conflict with or is in distress regarding, their sexual orientation or gender identity.
- To ensure that SCAs are adequately funded to support the ongoing care and treatment of patients, and that the position of GPs who do not feel they have the expertise or resource to share care with either NHS specialist services or the private sector is respected. To ensure that no clinic is allowed to ask for a commitment to acceptance of shared care as a prerequisite for referral.
- To fully implement the provisions of the Cass review in England and adoption of the principles it identifies across the nations of the UK, including the change in structure of services for children and young people and the need for further research, with full co-operation from adult gender clinics.
- Specifically, implement recommendation 23, that ‘NHS England should establish follow-through services for 17-25 year-olds at each of the Regional Centres, either by extending the range of the regional children and young people’s service or through linked services, to ensure continuity of care and support at a potentially vulnerable stage in their journey. This will also allow clinical, and research follow-up data to be collected’ and that ‘a follow-through service would benefit both this younger population and the adult population. This will have the added benefit in the longer-term of increasing the capacity of adult provision across the country as more gender services are established. This would be consistent with the other service areas supporting young people that are selectively moving to a ‘0-25 years’ service to improve continuity of care’.
- Specifically, implement recommendation 25, that ‘NHS England should ensure there is provision for people considering detransition, recognising that they may not wish to reengage with the services whose care they were previously under’.
- To review IT systems with safety concerns in mind. NHS systems should record codes for biological sex as well as gender identity, so that patients can be safely recalled for the appropriate screening according to the organs that they have, without compromising their gender identity. The use of a new NHS number when the gender marker is changed should be reviewed, as this carries the inherent risk of loss of relevant information.
- Educational and training bodies, commissioners and employers should provide training to support GPs and their teams. This training would help GPs to act as holistic generalists in this area and will not, in most cases, enable them to feel safe to initiate treatment for a patient who is not under the care of a GIC.
- The fundamental standards of care and principles of oversight and regulation applied by the Care Quality Commission (CQC) in England and equivalent bodies in the devolved nations, should be applied to all providers of gender identity services, whether they work in the NHS or privately.
Full position statement
- WHO: World Health Organization
- ONS: Office for National Statistics
- DSM: Diagnostic and Statistical Manual of Mental Disorders
- ICD-11: International Classification of Diseases 11th Revision
- GIC: Gender identity clinic
- GDC: Gender dysphoria clinic
- CYP: Children and young people
- GIDS: Gender Identity Development Service
- CAMHS: Child and adolescent mental health services
- GAH: Gender-affirming hormones
- GPwER: GP with Extended Role
This paper outlines some of the background and recent changes that affect the care of patients who seek help to do with their gender. It updates the RCGP’s position on the GP’s role with respect to patients experiencing gender incongruence and recommendations to improve future care for this cohort.
In 2019, RCGP Council approved a position on transgender care; this updated statement draws heavily on that agreed position and does not seek to propose any new policies, rather to present the significant changes in the external environment since 2019. Our 2019 statement, while referring to children and young people, predominantly focused on provision of care to adults. This update looks to comprehensively include care for children and young people in the light of the Cass review for England. The RCGP fed into the Cass Review to ensure the GP voice was represented. The Cass recommendations can only be understood in the context of the history of gender care for children and young people in the UK, a brief explanation of which is included in this paper. While the Cass review is specifically related to the English context, it is understood that the review will be considered in order to inform changes to existing policy and service provision in Scotland, Wales and Northern Ireland.
This document will (apart from when using direct quotations from other publications) use the same terms as the Cass review, i.e. gender incongruence rather than gender dysphoria, and gender-related distress to describe the feelings that commonly arise or intensify during puberty and lead to a person seeking help from the NHS1.
- Sex (World Health Organization, WHO1): refers to the different biological and physiological characteristics of females, males and intersex persons, such as chromosomes, hormones and reproductive organs.
- Gender (WHO2): refers to the characteristics of women, men, girls and boys that are socially constructed. This includes norms, behaviours and roles associated with being a woman, man, girl or boy, as well as relationships with each other. As a social construct, gender varies from society to society and can change over time.
- Gender identity (ONS3): Gender identity is a personal internal perception of oneself and, as such, the gender category with which a person identifies may not match the sex they were registered at birth. In contrast, sex is biologically determined.
- Gender dysphoria (DSM4): A marked incongruence between one’s experienced/expressed gender and assigned gender, of at least six months’ duration, as manifested by at least two or more of the following:
- A marked incongruence between one’s experienced/expressed gender and primary and/or secondary sex characteristics (or in young adolescents, the anticipated secondary sex characteristics)
- A strong desire to be rid of one’s primary and/or secondary sex characteristics because of a marked incongruence with one’s experienced/expressed gender (or in young adolescents, a desire to prevent the development of the anticipated secondary sex characteristics)
- A strong desire for the primary and/or secondary sex characteristics of the other gender
- A strong desire to be of the other gender (or some alternative gender different from one’s assigned gender)
- A strong desire to be treated as the other gender (or some alternative gender different from one’s assigned gender)
- A strong conviction that one has the typical feelings and reactions of the other gender (or some alternative gender different from one’s assigned gender)
- Gender incongruence of adolescence and adulthood (International Classification of Diseases 11th revision, ICD-115): Gender Incongruence of Adolescence and Adulthood is characterised by a marked and persistent incongruence between an individual’s experienced gender and the assigned sex, which often leads to a desire to ‘transition’, in order to live and be accepted as a person of the experienced gender, through hormonal treatment, surgery or other health care services to make the individual’s body align, as much as desired and to the extent possible, with the experienced gender. The diagnosis cannot be assigned prior the onset of puberty. Gender variant behaviour and preferences alone are not a basis for assigning the diagnosis.
- Gender incongruence of childhood (ICD-116): Gender incongruence of childhood is characterised by a marked incongruence between an individual’s experienced/expressed gender and the assigned sex in pre-pubertal children. It includes a strong desire to be a different gender than the assigned sex; a strong dislike on the child’s part of his or her sexual anatomy or anticipated secondary sex characteristics and/or a strong desire for the primary and/or anticipated secondary sex characteristics that match the experienced gender; and make-believe or fantasy play, toys, games, or activities and playmates that are typical of the experienced gender rather than the assigned sex. The incongruence must have persisted for about 2 years. Gender variant behaviour and preferences alone are not a basis for assigning the diagnosis.
- Transgender/Trans (NHS England7) An umbrella term to embrace the diverse range of identities outside the traditional male/female definitions. These include transgender, gender fluid and non-binary.
- Gender identity clinic (GIC)/gender dysphoria clinic (GDC) (NHS8,9): A gender identity clinic (GIC) is an NHS facility where services for transgender patients are offered, for example the provision of hormones and surgery. NHS wording is inconsistent, with some websites using GIC and some using GDC (gender dysphoria clinic). In Wales the provision is named the ‘Welsh Gender Service’. For consistency, this document will use the term GIC throughout.
- Cass Review1: A review about the care of children and young people (CYP) with gender-related distress in England. It does not relate to the care of adults. It was commissioned by NHSE and published an interim report in February 2022 and a final report in 2024. Significant changes in service provision have been recommended. As the review was commissioned by NHS England, decisions on services in the devolved nations will be made locally.
Adult gender services have been provided for patients from England, Scotland and Wales at the Tavistock and Portman clinic since 196610. A multi-disciplinary approach is used, focusing biological, psychological and social aspects of gender.
Services to treat CYP with gender incongruence started in the UK in 1989 with the opening of the Gender Identity Development Service (GIDS). It saw around 10 patients per year, mainly those registered male at birth, with a focus on therapeutic work; a minority progressed to hormone treatment at age 161 and it was accepted that for most, gender-related distress would not persist long-term. Persistence rates of 10 – 33 % were noted with most of the CYP growing up to be same-sex attracted adults who were not transgender1.
The focus of management changed in the 2000s after the Dutch protocol was published. This allowed for the use of puberty blockers in a small and carefully selected group of CYP, with the intention to buy time to think and improve future ability to pass as the preferred gender. To access this treatment, patients had to be at least 12, with life-long gender incongruence which had increased around puberty. They had to be psychologically stable, with no serious co-morbid psychiatric disorders and to have family support1.
Puberty blockers were first used in the UK in 2011, as an uncontrolled research study. There was no consistent improvement in psychological well-being or other mental health outcome measures (a contrast to the original Dutch study) and 98% of the group given puberty blockers went on to use gender-affirming hormones (GAH). In 2014, puberty blockers were routinely made available in clinical care in the UK, a move which the Cass review describes as having ‘unclear…rationale’. The strict criteria of the original Dutch study were not followed, and a much wider group of patients were treated, included those with no history of gender-related distress before puberty, and those with complex presentations including neurodiversity and mental health co-morbidities. Clinical practice also deviated from the NHSE service specification under which the clinics should have been operating, which required that research protocol parameters be used. Clinical practice was ‘disconnected from the clinical evidence base’.1
In this time period, referrals also increased significantly – in England and Wales, the number of referrals to child and adolescent GICs increased from 210 per year in 2011/12 to over 5,000 per year in 2021/22 and the proportion who are of the female sex has significantly increased11. For adults, there was a 240% increase in the five years to 201812. Increases have also been seen in Scotland13 and Northern Ireland14. This has placed immense pressure on GICs to meet demand.
The Cass Review. Final report. April 2024. Used under the terms of the Open Government Licence.
Current provision for adults varies by country of the UK:
- In England8 there are seven NHS Gender Identity Clinics (GICs), and three providers of adult genital reconstruction surgery.
- There are four GICs in Scotland15, all of which take referrals from a defined geographic area; the Sandyford clinic also accepts adult self-referrals16.
- Welsh GPs can refer adults to the Welsh Gender Service17 which assesses and refers on to a local gender team to co-ordinate treatment, using the NHSE surgical network if required.
- The Brackenburn Clinic in Belfast provides a Regional Gender Identity Service for adults in Northern Ireland18.
CYP in Northern Ireland are seen by the ‘Knowing Our Identity Service’19 and those in Scotland are seen by the Sandyford clinic16. CYP in Wales are seen by child and adolescent mental health services and transferred to adult services at the age of 1717.
Services for CYP in England have changed recently; in 2022, following the interim Cass report20, GIDS was closed and replaced with regional centres, administered by a national referral support service9. In April 2024, the final Cass report1 recommended that a regional multi-site service network be developed as soon as possible, with referrals to local specialist services being accepted only from secondary care (paediatrics or CAMHS) who would provide an initial assessment before referring on to gender services if appropriate. GPs would therefore no longer refer directly to a GIC for CYP. Regional gender services will work as an operational delivery network, supporting integration with other services (such as those for mental health and neurodiversity, as well as fertility and endocrine opinions where appropriate), to provide a more holistic approach and ongoing therapeutic support.
Proposed service models and referral pathways for CYP. The Cass Review. Final report. April 2024. Used under the terms of the Open Government Licence.
The UK lacks a nationally recognised training programme for gender identity healthcare. Although there are apprenticeship training models in several specialist GICs and guidelines are available from various organisations such as the British Association of Gender Identity Specialists (BAGIS)21, the European Professional Association for Transgender Health (EPATH)22 and the World Professional Association for Transgender Health (WPATH)23, the workforce needs to expand rapidly to meet service need. Concerns have been raised about some of these guidelines, with the final Cass review1 saying that the WPATH guidelines ‘were found…to lack developmental rigour [and]…cited…studies that were already deemed as low quality [and]…overstates the strength of the evidence [that gender-affirming interventions]…are safe and effective’. Guidelines in other countries including Sweden and Finland are much more cautious about the use of puberty blockers than the WPATH guidelines1.
The Royal College of Physicians has been commissioned by NHSE to develop a range of credentials for clinicians working in GICs; these will involve submission of a portfolio of evidence24.
Gender identity services are also needed for people who are uncomfortable or distressed by their biological sex or gender roles and behaviours assigned to them by society, and who may identify with a variety of gender types, but do not wish to access medical or surgical treatments.
The significant lack of evidence for treatments and interventions for CYP is a major issue which was investigated in depth by the Cass review1. Findings included the following:
- There ‘are many unknowns about the impact of social transition…it is unclear whether it alters the trajectory of gender development and… [the]…impact on mental health’.
- The evidence base for the use of puberty blockers in CYP ‘had already been shown to be weak’ before the review started, and there continues to be ‘insufficient and/or inconsistent evidence about the effects of puberty suppression on psychological or physical health’. Attempts to improve the evidence base by following through the 9,000 patients who were seen by GIDS ‘have been thwarted by a lack of co-operation from the adult gender services’. Within a few days of the publication of the report, it was announced that the adult clinics will now share their data and so this evidence can now start to be gathered25.
- One single Dutch study suggesting that ‘puberty blockers may improve psychological wellbeing for a narrowly defined group of children with gender incongruence’ was used as the basis for ‘the extension of this approach to a wider group of adolescents who would not have met the inclusion criteria for the original Dutch study’, with ‘some practitioners [abandoning] normal clinical approaches to holistic assessment’. Despite the fact that early studies on puberty blockers ‘did not demonstrate benefit [and showed] a lack of any positive measurable outcomes… puberty blockers moved from a research-only protocol to being available in routine clinical practice… the adoption of a treatment with uncertain benefits without further scrutiny is a significant departure from established practice’.
- Evidence for use of GAH in CYP is not of high quality, with ‘inconsistencies regarding suicidality and/or self-harm… moderate quality evidence that hormone treatment may improve psychological health in the short term [and] few studies that undertake long-term follow-up. Uncertainty remains about the outcomes for height/growth, cardiometabolic and bone health… evidence does not adequately support the claim that gender-affirming treatment reduces suicide risk’.
- The assessment process at GIDS has been criticised by the Cass review for having ‘a lack of… professional curiosity as to how the [CYP’s]… social circumstances may impact on their… decisions. Sexuality was not consistently discussed… notes rarely provided a structured history or physical assessment… it is not clear how fully and appropriately [ADHD and ASD] had been explored… the gender journey was rarely examined closely for…difficulty [or] regret or wishes to alter any aspect of their gender trajectory’. GIDS chose not to take part in the international survey done as part of the Cass review.
There are also no guidelines available to advise those who wish to detransition; this population often has unmet physical and mental healthcare needs and may not want to engage with the services that supported them to transition1,26. This puts GPs in a very difficult position when trying to support patients and their families, either before referral, whilst on a long waiting-list, or if they present with regrets about their transition. The final Cass review has recommended that NHS England ensure provision for those who want to detransition1.
The General Medical Council (GMC) advises that doctors promptly refer patients requesting treatment for gender dysphoria to a specialist gender service27, however it is unlikely that a prompt referral will result in the patient being seen promptly.
Under the NHS Constitution for England, the maximum waiting time for an initial specialist appointment following referral is 18 weeks28. Despite this, as of February 2024, one GIC in England were booking appointments for people referred in late 201829 and as of April 2024, another clinic quoted 5,246 people on their standard waiting list30. The situation was better in Wales, with adult patients referred in Aug 2022 being seen in Nov 202317, and in some areas of Scotland, with one clinic quoting a two-year waiting list31, but worse in Northern Ireland where people referred in 2017 were being sent appointments in 202418.
A report on transgender equality published by the House of Commons Women and Equalities Committee in January 201632 found ‘serious deficiencies in the quality and capacity of NHS gender identity services’ and expressed concern about ‘the apparent lack of any concrete plans to address the lack of specialist clinicians in this field’. The Committee reports the uneven geographical distribution of GICs, meaning that people need to travel long distances to access treatment. Concern was also raised about the attitude of some GPs, with reference made to a lack of training. In 2023, a parliamentary briefing33 noted that ‘waiting times are contributing to… distress’ and that ‘care on the waiting list is minimal…adults on the waiting list can, in some places, access peer or community support groups, but there is significant geographical variation’.
Of the 108,100 respondents to the 2018 Government Equalities Office (GEO) National LGBT Survey34, 13% of respondents were transgender. Of these respondents, 38% accessing general healthcare services reported a negative experience due to their gender identity. Some of the respondents specifically called for healthcare professionals to be trained in not making assumptions about their patients’ gender identity.
Of the 2,900 respondents who elaborated on their experiences of gender transition and gender identity services, the emerging overall view was of hard-to-access services, and a lack of knowledge among GPs about what services are available and how to access them. Of all the trans respondents who had tried accessing gender identity services, 80% said that access had not been easy, with the majority of these (68%) reporting that waiting times had been too long. The survey also found that 16% of trans respondents had gone outside the UK to pay for healthcare or medical treatment, and a further 50% were considering it.
The Cass review1 spoke to a wide variety of patient and their families, including those who felt empowered by the decision to transition and those who deeply regretted it. The Review notes that some children and young people were ‘really clear that [they] want much better advice on the options available to [them] and the risks and benefits of different courses of action [and that] others…have said you just want access to puberty blockers and hormones as quickly as possible’. Similarly, among parents, ‘some have fought to get their children onto a medical pathway and have spoken about how frustrated they have felt to have to battle to get support. Others have felt a medical pathway was entirely the wrong decision for their child and have described their dismay about actions taken without their consent and in ignorance of the various other difficulties their child may have been through, such as loss of a parent, traumatic illness, diagnosis of neurodiversity and isolation or bullying in school’.
Bridging prescriptions
Patients who are not under the care of a GIC may request that the GP prescribe a ‘bridging prescription’ or offer blood tests to monitor hormones bought online. This is recommended in relation to adult patients by a 2013 Royal College of Psychiatrists (RCPsych) document35. However, this guidance is due to be updated and may not reflect the latest context, including growing waiting times for specialist care. Notably, the current WPATH guidance suggests that bridging should be ‘a limited (1-6 month) prescription’ which does not fit with the UK context, where patients wait several years to be seen. More recently, the GMC has published extensive guidance in relation trans healthcare, most recently updated on 30 January 202427. This includes information about prescribing on the recommendation of a specialist and establishing shared care as well as a section on bridging prescriptions which ‘is aimed at reassuring doctors who wish to prescribe for their transgender and gender diverse patients that it wouldn’t be against our guidance to do so, but it does not require doctors who do not feel that prescribing would be of overall benefit to a patient to go down a particular treatment route’.2 If a GP does decide to do this, they should ‘consult local policy, where it exists, and seek advice from a specialist service provider or an experienced colleague.’
Patients who are experiencing gender incongruence should not have to resort to self-medication without the advice of a gender identity specialist, but until waiting lists are shorter, this is likely to continue to happen. GPs should not be expected to fill the gaps in commissioned gender identity specialists and clinics.
The RCGP recognises that some GPs have particular expertise, or an extended role, in the area of transgender care. Such GPs may feel competent in providing prescriptions and this document is not intended to stop them doing that, in line with the instruction in Good Medical Practice36 that we work within the limits of our competence. However, many GPs will not have a special interest or have undergone additional training, and therefore may not feel confident or competent to prescribe without specialist input and advice. We recognise that when a patient’s needs cannot be met, wherever possible they will need to be directed to a suitably competent colleague by their GP.
Prescriptions (October 2024)
- Given that the term “bridging prescription” has not been formally defined and is not helpful in the patient pathway, we will be referring to this area more generally as prescribing in future.
- Where GPs are considering prescribing, this should form part of a holistic assessment taking into account all conditions that may be present and the interplay of these conditions in the presenting features.
- Additionally, it is imperative to ensure that other conditions that may be relevant are diagnosed and considered. This is important as a prerequisite before any prescribing can take place. Therefore, we propose that prescribing only takes place after a holistic assessment.
- Where GPs have the competence to do so and it is in the best interests of the patient, taking into account the risks to the patient, the RCGP would support them initiating prescriptions. However, in many cases, in the context of specialist waiting lists of several years and the risks associated with long term prescribing without specialist team support, these factors need to be carefully considered when deciding whether prescribing hormones by the GP would be in the best interests of the patient. Patients with gender-related distress deserve a full, multi-disciplinary assessment by a specialist team It is unreasonable for patients to have to seek to rely on cumulative prescriptions from the same or different prescribers as a mitigation to excessive waiting times to see and obtain prescriptions from a specialist GIC.
- This statement was not intended to apply to patients who are already established on such prescriptions. In instances where patients have been initiated and established on these medications, their prescriptions should not be abruptly stopped, as this could result in adverse effects. We would expect that clinical judgment would be applied to these individual situations. Some of the issues identified above may also be relevant in this case; for example, if a patient has been initiated on hormones by a private overseas clinic, where the clinical considerations and decision-making process may vary.
Safeguarding
GPs face challenges in addressing the needs of children and young people under the age of 16 who are experiencing gender incongruence or are in the process of transitioning to another gender. These challenges include the vulnerabilities and wider mental health issues of young people and the lack of a robust evidence base for interventions. Parental and carer involvement in the care of these patients is crucial and adds another layer of complexity to the GPs role.
It would generally be expected that, for patients under the care of a consultant, any safeguarding issues noticed in secondary care would have been actioned, but this may not be the case for those who have been seen by GIDS. The Cass Review1 acknowledges that there are a small number of cases in which ‘the child’s gender identity was consciously or unconsciously influenced by the parent’. It also reminds us that ‘safeguarding issues can be overshadowed or confused when there is focus on gender or in situations where there are high levels of gender-related distress’ and that ‘when the multi-professional review group (MPRG) began reviewing cases, the Tavistock team were unwilling to comply with MPRG safeguarding reporting requirements, but this situation has been partially resolved…however the MPRG continue to be very concerned about the GIDS teams lack of apparent professional curiosity or concern in relation to risk and safeguarding’. In 2021, GIDS was rated inadequate by the CQC, with concerns about risk management among other issues. GPs should not therefore assume that safeguarding issues have been addressed for patients who have been under the care of GIDS, and it remains important that GPs refer if there are any concerns.
Changes to the gender marker on the notes
GPs also face difficulties with current IT systems in relation to referrals and screening. For example, a trans male will not be recalled for cervical screening on the national recall programme, despite possibly still having female reproductive organs. The Cass review1 has raised concerns that the need for a new NHS number when gender is changed ‘makes it more difficult to identify the long-term outcomes for a patient population for whom the evidence base is currently weak’ and suggests that ‘the NHS and the Department of Health and Social Care needs to review the process and circumstances of changing NHS numbers and find solutions to address the clinical and research implications’.
Up-to-date IT systems and associated IT training is needed to enable GPs and other healthcare professionals to treat trans patients and patients with gender dysphoria in a safe and respectful manner (for example, documenting generalist and specialist advice in writing as part of the patient record, maintaining safe access to screening programmes such as smears after a patient’s gender has been changed on records). NHS systems should record codes for biological sex as well as gender identity, while ensuring all patients are afforded the right to express their preferences for how they wish to be named and referred to by their GP and other healthcare professionals.
Concerns about conversion therapy
The RCGP is a signatory of the Memorandum of Understanding on Conversion Therapy (MoU)37, the ‘primary purpose [of which is] a commitment to ending the practice of ‘conversion therapy’ in the UK’. The MoU defines conversion therapy as ‘an umbrella term for a therapeutic approach, or any model or individual viewpoint that demonstrates an assumption that any sexual orientation or gender identity is inherently preferable to any other, and which attempts to bring about a change of sexual orientation or gender identity, or seeks to suppress an individual’s expression of sexual orientation or gender identity on that basis’.
The Cass Review1 makes it clear that ‘the intent of psychological intervention is not to change the person’s perception of who they are but to work with them to explore their concerns and experiences and help alleviate their distress… it is harmful to equate this approach to conversion therapy as it may prevent young people from getting the emotional support they deserve’. The British Psychological Society has also noted their concerns that a ban on conversion therapy may prevent identity exploration and stop professionals from providing ethical forms of therapy45.
The Cass Review is in line with the MoU37 which ‘supports therapists to provide appropriately informed and ethical practice when working with a client who wishes to explore, experiences conflict with or is in distress regarding, their sexual orientation or gender identity.’ The MoU is clear that it ‘is not intended to deny, discourage or exclude those with uncertain feelings around sexuality or gender identity from seeking qualified and appropriate help. This document supports therapists to provide appropriately informed and ethical practice when working with a client who wishes to explore, experiences conflict with or is in distress regarding, their sexual orientation or gender identity. Nor is it intended to stop psychological and medical professionals who work with trans and gender questioning clients from performing a clinical assessment of suitability prior to medical intervention. Nor is it intended to stop medical professionals from prescribing hormone treatments and other medications to trans patients and people experiencing gender dysphoria’ and notes that ‘for people who are unhappy about their sexual orientation or their gender identity, there may be grounds for exploring therapeutic options to help them live more comfortably with it, reduce their distress and reach a greater degree of self-acceptance. Some people may benefit from the support of psychotherapy and counselling to help them manage unhappiness and to clarify their sense of themselves. Clients make healthy choices when they understand themselves better’.
As a signatory to the MoU, the RCGP fully endorses the concept that therapists in primary and secondary care must be allowed to fully explore patient’s uncertainties, and any mental health co-morbidities or neurodiversity, without being accused of conversion therapy1,38,39.
GPs are expert generalists; the provision of detailed advice about gender identity issues and associated treatments does not fall within the remit of a GPs education and training. The RCGP curriculum does however include the need to provide ‘high-quality, holistic and comprehensive care to…transgender people’40. The RCGP eLearning site has a course on transgender care, which is being updated in light of the Cass review41. GPs should be aware that a patient may find the process of approaching a healthcare professional to discuss their gender identity to be difficult or distressing. GPs and their practice teams should approach these patients openly, respectfully and sensitively, with an awareness and understanding that a person’s outward appearance may not necessarily correspond to their gender identity, particularly at early stages of the person’s journey to exploring their gender identity.
The RCGP considers that the role of the GP includes the following:
- To provide a holistic approach, contextualising a person’s presentation of gender incongruence with other conditions and within their broader environment.
- To provide appropriate primary care related to gender-related distress or gender incongruence. This may include the use of non-oestrogen hormonal contraception to manage distressing periods in those who are transitioning from female to male.
- To provide appropriate signposting to patients presenting with gender incongruence alongside other social or medical issues. This may include referral to mental health services or engaging with social care, safeguarding, social prescriber or sexual health colleagues.
- To ensure that all patients can express their preferences for how they wish to be named and referred to and that these are respected.
- To promptly refer, where appropriate, to a GIC, or to the appropriate secondary care service if the patient is aged under 18.
- To liaise and work with GICs in the same way as with any other specialist. This includes consideration of prescribing under a shared care agreement (SCA). It is important that SCAs are agreed upon by all parties involved, with consent from all parties, given on a willing and informed basis42, ensuring the appropriate levels of resource42,43, competence and expertise are established, as informed by the patient’s level of medical risk. NHS bodies need to ensure that local collaborative care arrangements and locally commissioned services are adequately funded to support the ongoing care and treatment of patients e.g. including integrated services that meet the mental and physical needs of the patient. When responsibility for ongoing medical monitoring and prescribing is assumed by a GP, the limitations of this need to be recognised and mitigated.
Collaborative care (October 2024)
- We recognise that the term “shared care” may not take into account locally agreed arrangements that are shown to be safe and effective. Such types of collaborative arrangements that recognise the need for a patient-focused solution could be better be described as collaborative care.
- Collaborative care is available for a variety of conditions and is not exclusive to gender incongruence. It is also well suited to define the care within the context of local integrated services. Collaborative care for gender incongruence should follow the same lines as for any other condition wherein it takes place by arrangement and agreement. There should be a document that describes the nature, responsibilities and boundaries of the collaborative care agreement in the patient’s notes.
- In line with GMC guidance (external PDF) and NHS England’s “Responsibility for prescribing between Primary & Secondary/Tertiary Care” guidance (external PDF) which has been endorsed by RCGP, such care for any condition should only be carried out if:
- It is in the best interest of the patient: The best interest, agreement and preferences of the patient should be at the centre of any collaborative care agreement and their wishes followed wherever possible.
- The patient or their carers have the opportunity to ask questions and explore other options if they don’t feel confident that collaborative care will work for them.
- If the specialist considers the patient’s condition to be stable or predictable.
- The GP feels clinically competent.
- The GP has agreed to this in each individual case, and the specialist will continue to provide prescriptions until a successful transfer of responsibilities. The GP should confirm the agreement and acceptance of the prescribing arrangement and that supply arrangements have been finalised.
- Adequate training and educational support is in place for the GP, e.g. regarding administration of the medicine etc. Information on how to access this support should be provided in the collaborative care prescribing guidelines.
- The resources and capacity to ensure consistent delivery are determined before any such collaborative care prescribing is implemented.
- GPs are responsible for the prescriptions they sign and are accountable for their decisions and actions when supplying or administering medicines (external PDF). See our wider guidance on the interface between primary and secondary care.
- To recognise that the family members of a patient experiencing gender incongruence also face significant challenges and refer these family members to further support services where appropriate.
The RCGP recognises that some GPs have particular expertise, or an extended role, in the area of transgender care and supports them to act in their patient’s best interests, within the limits of their competence. For the majority of GPs, without this expertise or extended role, the RCGP considers that the role of the GP does not include the following:
- Prescribing bridging prescriptions for those on the waiting list for a GIC.
- Prescribing puberty blockers for a patient aged under 18, even on a shared care basis, given the concerns about the evidence base in this area as well as the specialist expertise required to monitor dosage and side effects. The Cass Review1 notes that ‘the Review has already advised that because puberty blockers only have clearly defined benefits in quite narrow circumstances, and because of the potential risks to neurocognitive development, psychosexual development and longer-term bone health, they should only be offered under a research protocol. This has been taken forward by NHSE and the National Institute for Health and Care Research (NIHR)’ and that ‘if an individual were to have taken puberty blockers outside the study, their eligibility may be affected’. This precludes GPs from ever prescribing puberty blockers, excepting any GPs working on clinical trials in this area.
- Prescribing gender affirming hormones for a patient aged under 18, even on a shared care basis, given the concerns about the evidence base in this area as well as the specialist expertise required to monitor dosage and side effects. The Cass Review1 advises that ‘NHS England should review the policy on masculinising/feminising hormones. The option to provide masculinising/feminising hormones from age 16 is available, but the Review would recommend extreme caution. There should be a clear clinical rationale for providing hormones at this stage rather than waiting until an individual reaches 18’. In view of this, the RCGP view is that prescribing of gender-affirming hormones should generally only be done by specialists.
- For both puberty blockers and gender affirming hormones, no attempt should be made to persuade a GP to prescribe by citing, for example, distance between the patient and the clinic - it is up to the clinic to facilitate electronic prescribing or some other means of arranging prescriptions.
- Carrying out blood tests on behalf of secondary care or making decisions about how those blood tests affect hormone doses – NHSE advice44 and primary/secondary care interface documents45 make it clear that a clinician who wants to request a test should do it themselves. Again, it is up to the clinic to manage issues of distance by liaising with the patient’s local trust/phlebotomy services directly.
- Sharing care with the private sector46, unless the GP practice has made their own decision to do so and feels that it is safe and resourced.
The RCGP calls for the following changes at national level:
- To review the service specification for adult GICs and ensure that the commissioning of gender identity services is sufficient to support the demand for services for patients and advice and good communication to GPs.
- To ensure that services for adults and CYP take a holistic approach, considering neurodiversity, adverse childhood experiences and mental health co-morbidities. We would support innovative models including those which use a ‘hub and spoke’ model to provide care from local clinics run by GPs with Extended Roles (GPwERs) with supervision from a consultant in the field. The RCGP would be open to exploring the creation of a framework for a GPwER in this area.
- To ensure that patients who present to their GPs with gender-related distress have access to appropriate psychological therapy within the community, whilst waiting to be seen in a GIC or as stand-alone therapy for those who do not wish to be referred to a GIC. As noted in the Memorandum of Understanding on Conversion Therapy to which the RCGP is a signatory, while there must be commitment to ending the practice of conversion therapy in the UK, there must also be appropriate support for therapists to provide appropriately informed and ethical practice when working with a client who wishes to explore, experiences conflict with or is in distress regarding, their sexual orientation or gender identity.
- To ensure that SCAs are adequately funded to support the ongoing care and treatment of patients, and that the position of GPs who do not feel able or resourced to share care with either the NHS or the private sector is respected. To ensure that no clinic is allowed to ask for a commitment to acceptance of shared care as a prerequisite for referral.
- To fully implement the provisions of the Cass review in England and adoption of the principles it identifies across the nations of the UK, including the change in structure of services for children and young people and the need for further research, with full co-operation from adult gender clinics.
- Specifically, implement recommendation 23, that ‘NHS England should establish follow-through services for 17-25 year-olds at each of the Regional Centres, either by extending the range of the regional children and young people’s service or through linked services, to ensure continuity of care and support at a potentially vulnerable stage in their journey. This will also allow clinical, and research follow-up data to be collected’ and that ‘a follow-through service would benefit both this younger population and the adult population. This will have the added benefit in the longer-term of increasing the capacity of adult provision across the country as more gender services are established. This would be consistent with the other service areas supporting young people that are selectively moving to a ‘0-25 years’ service to improve continuity of care’.
- Specifically, implement recommendation 25, that ‘NHS England should ensure there is provision for people considering detransition, recognising that they may not wish to reengage with the services whose care they were previously under’.
- To review IT systems with safety concerns in mind. NHS systems should record codes for biological sex as well as gender identity, so that patients can be safely recalled for the appropriate screening according to the organs that they have, without compromising their gender identity. The use of a new NHS number when the gender marker is changed should be reviewed, as this carries the inherent risk of loss of relevant information.
- Educational and training bodies, commissioners and employers should provide training to support GPs and their teams. This training would help GPs to act as holistic generalists in this area and will not, in most cases, enable them to feel safe to initiate treatment for a patient who is not under the care of a GIC.
- The fundamental standards of care and principles of oversight and regulation applied by the Care Quality Commission (CQC) in England and equivalent bodies in the devolved nations, should be applied to all providers of gender identity services, whether they work in the NHS or privately.
- The Cass Review. Final report. April 2024
- World Health Organization. Gender and health
- Office for National Statistics. Gender identity. June 2020
- American Psychiatric Association. Gender dysphoria diagnosis. November 2017
- ICD-11 for Mortality and morbidity Statistics. January 2024. Gender incongruence of adolescence or adulthood
- ICD-11 for Mortality and morbidity Statistics. January 2024. Gender incongruence of childhood
- NHS England. NHS population screening information for trans and non-binary people. January 2023
- NHS. How to find an NHS gender dysphoria clinic. May 2020
- National referral support service for the NHS gender incongruence service for children and young people. April 2024
- The Tavistock and Portman NHS Foundation Trust. Gender identity clinic
- UK Parliament. Factors shaping gender incongruence and gender dysphoria, and impact on health services. August 2023
- Torjesen I. Trans health needs more and better services: increasing capacity, expertise and integration. BMJ 2018; 362: 3371
- Scottish Government. Supporting NHS gender identity services. December 2021
- Health and social care. Gender identity service. October 2022
- National gender identity clinical network for Scotland. Gender identity clinics. 2024
- NHS Greater Glasgow and Clyde. Gender service at Sandyford
- Welsh gender service. November 2023
- Belfast health and social care trust. Brackenburn clinic
- Health and Social care. Gender identity service
- The Cass Review. Interim report. February 2022
- British Association of gender identity specialists
- European professional association for transgender health
- World professional association for transgender health
- Royal College of Physicians. Professional certificates for gender identity healthcare professionals
- NHS England. Review of NHS adult gender dysphoria clinics. April 2024 (external PDF)
- The Times. April 2024
- General Medical Council, ‘Trans healthcare’, Ethical hub, 2023
- Department of Health and Social Care. Consultant-led treatment: right to start within 18 weeks. October 2022
- Sheffield health and social care NHS Foundation Trust. Gender identity clinic. January 2024
- Leeds and York partnership NHS Foundation Trust. November 2023
- Lothian Sexual health. Waiting times
- Parliament. House of Commons Women and Equalities Committee (2016) Transgender Equality. (HC 390). London: The Stationery Office Limited (external PDF)
- UK Parliament. POSTbrief53. Aug 23. Factors shaping gender incongruence and dysphoria, and impact on health services (external PDF)
- Government Equalities Office. National LGBT survey summary report. July 2018 (external PDF)
- RCPsych. Good practice guidelines for the assessment and treatment of adults with gender dysphoria. October 2013 (external PDF)
- GMC. Good Medical Practice. January 2024
- British Association for counselling and psychotherapy. Memorandum of understanding on conversion therapy in the UK. Collaborative publication. April 2024
- D'Angelo R. Supporting autonomy in young people with gender dysphoria: psychotherapy is not conversion therapy. Journal of Medical Ethics Published Online First: 18 November 2023
- Mind. Mind response: banning conversion therapy consultation. Feb 2022 (external PDF)
- The RCPG curriculum. Being a general practitioner. 2019
- RCGP Learning. Gender Variance. 2024
- NHS England. Responsibility for prescribing between Primary & Secondary/Tertiary Care. 2018 (external PDF)
- BMA. Role of GPs in managing adult patients with gender incongruence. 2022 (external PDF)
- NHS England and NHS improvement. The interface between primary and secondary care. Key messages for NHS clinicians and managers. July 2017 (external PDF)
- NHS Cheshire and Merseyside. Consensus on the primary and secondary care interface. June 2022
- BMA. General practice responsibility in responding to private healthcare. August 2023
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