Guidance from the General Pharmaceutical Council (GPhC)
Having reviewed the guidance from the UK’s General Pharmaceutical Council (GPhC) in detail, we have identified the areas which may be cause for concern and in which we may be able to provide reassurance.
These are as follows
Prescriptions may be sent electronically in some cases
Our prescriptions meet the UK requirements for electronic prescriptions as set out in the HMR 2012 Regulation 219. Our prescribers sign with an advanced electronic signature which is uniquely linked to the prescriber and through which they can be identified. It is created via means that remain under the sole control of the prescriber and it is linked to the data in such a way that any changes can be identified. The signature is created in an electronic form using an advanced electronic signature and is transferred to the pharmacy via an electronic prescribing system.
The prescriber may not be registered with a UK regulator
All GenderGP prescribers are registered in their home country where the prescription is issued and can lawfully issue prescriptions online to people in the UK.
There may be the perception that we are a provider that is trying to circumvent regulatory oversight in the UK
We can assure you that, as a global organisation that has been supporting trans individuals for the past five years, our only aim is to ensure those that need care have access to care. We operate within all required regulation and only seek to work with regulators and not in any way circumvent their influence.
There may be the perception that the medication we prescribe requires monitoring in a way other than routine blood testing, or that it is in some way dangerous
None of the medicines that we prescribe fall into the categories of medicines that are not suitable to be prescribed online. A full list of medications prescribed can be found here. It is well known that many medications that are prescribed are unlicensed for use in trans healthcare. You can read GMC guidance about this here, and the GPhC advice here. All of our clinicians prescribe in line with The Endocrine Society Guidelines for the Care of Transgender Patients.
There may be the perception that we are not following UK standards of care and prescribing
Our goal is to be fully transparent as such you can find plenty of information to support the global standards of care that we follow on our website. Indeed we have a Pharmacy Hub on our website which has been set up to support our pharmacy colleagues.
The following pages may be of particular interest:
- Our prescribing protocols can be found here.
- Our approach to assessments can be viewed here.
- The Clinical Guidelines we follow can be viewed here.
- Our monitoring protocols can be found here.
We encourage all of our patients to share their health information with their primary care doctor in relation to their transition, but sadly, due to the high levels of transphobia that exist in the UK, not all feel safe to do so. This is something that was identified and covered in detail in the Women and Equalities report on transgender equality which was published in 2016.