NHS consultation on GICs (England)

About the consultation

NHS England have a consultation on their draft service specification and commissioning policy for Gender Identity Services. This will affect how all gender identity services (Gender Clinics, etc) are provided in England and what services you can get.

The consultation is open for 30 days (until 23 April) and we want to get as many replies in as possible.

The details are here – note there are 2 documents for Gender Identity Services – a service specification and a commissioning policy.

The response page is here – you need to reply separately for each document.

Here are some of our ideas – you might want to add your own:

Suggested responses

The improvement in the treatment of nonbinary people compared to the previous (Interim) version is huge. We weren’t mentioned before, now it specifically mentions us under most (but not all) sections and generally says we should be treated and have our dignity respected. But there is still some lack of equity of treatment with binary-gendered trans men and women:

  • Nonbinary people are mentioned as eligible for some treatments but not others (Genital surgeries, hair removal).
  • The policy requires specialists to look for consistency of identity – we would like them to explicitly recognise that someone can be ‘consistently’ gender fluid, bigender etc and qualify for treatment.
  • Treatments for nonbinary people are described as more of a “complex clinical judgment” involving a greater number of gender specialists – this is discriminatory.
  • We would like them to clearly allow different pathways of treatments for nonbinary people – some nonbinary people might need a combination of treatments that might not usually be expected to go together in a binary trans person’s care plan.
  • We are concerned that the policy treats nonbinary and non-gendered/agender people as two separate categories with fewer treatments (only ‘gender neutralising’ treatments) recommended for ‘agendered’ people – All trans people should have access to whichever treatments they need regardless of how they identify.

Overall the policy aims to relieve the gender dysphoria of and increase the quality of life of nonbinary people. Their efforts to recognise and include nonbinary people and respect our dignity are a positive step, but they have left areas of ambiguity and omission that threaten those aims.

In general, the policy is still discriminatory for all trans people in terms of the amount of assessment required to access services relative to cis people accessing the same treatments. This could be seen as discrimination under the Equality Act 2010.  For example:

  • The rules for accessing bilateral mastectomy are different for cis women wanting the procedure as Risk Reducing Surgery compared to those for men and nonbinary people wanting the procedure as gender-related surgery. This is direct discrimination.
  • Trans people of all genders can be refused hormone treatments by their GP because they aren’t approved for use as part of gender reassignment, while cis people would not be refused the same medications if they went to their GP with low hormone levels. This is direct discrimination.
  • The rules regarding consent are routinely breached for trans people, who are obliged to undergo psychiatric assessment. This is direct discrimination.

Access to treatment for all trans people should be based on informed consent and not implied gatekeeping. Nonbinary people should not be singled out for extra scrutiny. An informed consent model would remove discrimination towards us.

We would like to thank Zoe Playdon for her suggestions about the equality act.

Also if you have more suggestions for things we should be commenting on please do tell us.

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