In the UK the Care Quality Commission (CQC) has an important role in making sure healthcare services provide people with safe and high-quality care. They also undertake to offer guidance to General Practitioners (GPs) and other Healthcare Professionals (HCPs) on major quality issues in health and social care.
On the 22nd of September, the CQC published amended guidance for GPs in relation to how they should support their transgender patients. The guidance included the suggestion that GPs should discourage their patients from accessing their treatment and support via private specialists, and that GPs should also actively refuse to be involved in routine hormone monitoring where a patient is receiving private prescriptions.
Naturally, as a major provider of Gender Affirming healthcare (GAH) with thousands of active patients in the UK, GenderGP found this particular update particularly highly concerning, especially since a majority of our service users are only able to effectively access timely affirming care through a shared care partnership between us and their NHS GP.
At the time of publishing many organisations, including the LGBT Foundation, echoed our concerns and requested that the CGC take the opportunity to review community feedback.
The CQC reacted by almost immediately taking the guidance offline and committing to not releasing any further guidance on this matter without engagement from those with lived experiences and those representing trans people.
At time of publishing this article, the following text appears on the ‘Adult trans care pathway: what CQC expects from GP practices’ section of the CQC website
“Please note we are responding to some feedback on this section of the document. It has been temporarily removed for further engagement on the content”
Further to their promise to consult with organisations such as GenderGP, we wrote to CQC Chief Executive Ian Trenholm outlining our concerns and requesting that our views be considered as part of the consultation.
Dear Ian Trenholm
On the 22nd of September, we were made aware that the Care Quality Commission had published amended guidance for General Practitioners in relation to how they should support their transgender patients (link).
As a specialist provider of gender affirming healthcare we welcome any attempt to ensure trans and gender diverse people are able to access timely and respectful treatment and support. As such it was with a considerable degree of concern that we read the update to your guidelines which suggested that GPs should discourage their patients from accessing their treatment and support via private specialists. Further, the suggestion that GPs should actively refuse to be involved in routine hormone monitoring where a patient is receiving private prescriptions, was also very troubling due to the fact that many of our service users are only able to access private care in this way.
As you are no doubt aware, access to gender affirming healthcare for trans and non-binary individuals remains a significant challenge in the UK and we are committed to effecting meaningful change to ensure that every individual who needs it, has access to support and treatment without discrimination, prejudice, or gatekeeping.
In light of this we are pleased to see that this update has since been taken down for review. We understand that the LGBT Foundation has also recommended that the CQC consult with those representing this patient group in order to ensure patient safety and inclusion.
To that end, we wanted to offer our insights and expertise in this matter. We support thousands of trans and non-binary individuals every year, enabling them to access the care that they have to wait years to access on the NHS. We would be more than happy to share our insights and expertise should you be looking for additional input on your revised guidance.
In a recent communication between our organisation and Dr Jonathan Leach, the Royal College of General Practitioners Honorary Secretary, he confirmed that he would expect that the sharing of information between general practitioners and private providers to be no different than it would be between NHS colleagues.
Unfortunately, we have found that whilst there are many GPs who welcome working with services like ours, due to the additional expertise we are able to offer to ensure the very best level of care for our mutual patients, there are sadly still those who refuse to work in this way. Much of this reluctance is fuelled by the lack of education provided in this particular field of medicine and the often contradictory guidance coming from UK regulators.
We very much look forward to contributing to any CQC consultation regarding guidance for GP practices and we warmly invite you to join us in an ongoing discussion about how NHS and private providers can best help their mutual patients.
We look forward to receiving your response.
Yours Sincerely
Adi Daly-Gourdialsing – Current Affairs & Engagement Lead – GenderGP
As an organisation GenderGP advocates on behalf of our patients and clients on important matters that directly and indirectly affect them, as such we will continue to engage with the CQC on this issue and ensure we update our audiences as and when we’re aware of any developments.
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