General Pharmaceutical Council
25 Canada Square
Sent by email 08.02.21
Dear Mr Rudkin,
Pharmacies need the support of the GPhC in providing services to transgender patients.
I am writing to you in my capacity as Chief Operating Officer of GenderGP, following your recent targeted inspections of two pharmacies working with our organisation.
There is extreme UK social, political and moral unrest about the medical interventions required for transgender and gender diverse patients, but that should not be permitted to colour judgement or affect care.
The use of puberty blockers and gender-affirming hormones is well-established in medical evidence and protocol, but UK anti-trans groups are succeeding in creating an environment of fear and suspicion that leaves patients without medical care and at risk of suicide, self-harm and poor mental health.
There is a very real perception of discrimination by the trans community, and we feel that it is vital that this minority group feels that regulatory action is taken to protect them, not impede their access to care.
Any actions undertaken by the GPhC in respect of those pharmacies who are dispensing to trans patients MUST be based on evidence, best-practice and in line with regulation and expectation for other medical interventions in young people.
Just because gender reassignment is a particularly newsworthy topic, does not mean that patients should be restricted in their access to care.
In your interactions with our partner pharmacies you have cited the following reasons why they should perceive GenderGP patients to be at risk:
- Management of risk
- Lack of safeguarding
- Risks to patient safety
- The volume and type of medicines supplied
- The age range of patients
- Potential vulnerability of the patients
- Additional risks of working with prescribers based in the EEA
- Working outside of UK regulatory oversight
- Risk assessment
- Protection of patient safety
If you have direct questions regarding any of these areas we are more than happy to provide the evidence you need to satisfy yourself that the necessary protections are in place. Let’s start a conversation to help these patients.
In the meantime, we ask that you view pharmacies who provide care to trans patients with the same eye as you would those providing care to other similarly politicised groups. We ask you to put aside personal opinion, and really ask yourself whether the risk to patients would be greater by having safe, regulated medical solutions in place or by leaving these patients without essential care.
As well as a dangerous lack of available gender-specialist healthcare in the UK, there is also a real climate of fear. There is fear from parents being criticised for supporting their trans child. There is fear amongst doctors for being reported to the GMC for providing care to trans youth. There is fear amongst pharmacists about how you, their regulator will respond, if they are dispensing medication and providing support to trans youth.
However, we must never forget that the REAL fear should be for those individuals who are at risk if their access to healthcare is stopped: young transgender people.
Every trans adult in the UK that is identifiable as trans from their appearance or their voice, and faces daily discrimination as a result, was once a trans child.
Today, there are healthcare options available to trans youth that weren’t available 20 years ago. Proven protocols have been recommended by leading experts and the World Professional Association of Transgender Health. The National Health Service has a duty to provide this service and the Equality Act dictates against discrimination.
These medications limit the significant and life-altering changes of puberty and allow a trans adolescent to go through puberty with their peers. They bring mental health scores in line with those of cisgender adolescents, and they reduce the risk of harm.
NHS youth services have been told by the CQC that their services and waiting times must improve significantly. GenderGP provides a global service which operates in line with international best practice. There is no evidence that our service is anything other than life-saving, yet pharmacies that dispense our prescriptions are being directly targeted by your organisation.
If you would like to meet some of the young people and families who are impacted by the regulatory actions that you undertake in their name, we would be happy to help facilitate this. Indeed we will do all we can to aid you in any education, real-life experience or advocacy work.
We ask that you fly the trans flag at full mast and show the trans community that you will indeed work to assure and improve standards of care for transgender people using pharmacy services; but that does not mean cutting off their medication and leaving them with no alternative but to turn to unregulated providers risking their health – and worse.
Chief Operating Officer