On October 20th 2022, NHS England announced a new “Interim service specification for specialist gender dysphoria services for children and young people”, and with it a public consultation running until December 4th 2022. This interim service specification was ostensibly a response to the interim report of the Cass review, although it has been subject to a relatively greater deal of controversy as many professional trans health bodies have united to condemn the draft specification. While the Cass review interim report was received with cautious critical welcome by trans rights groups, the interim service specification by NHS England has been robustly condemned by an international coalition of every professional transgender health body, with strong criticism raised also by British trans rights groups.
A number of anti-trans campaign groups have responded by calling on supporters to lobby the consultation process. They have provided model submissions to followers, which we summarise below. The listing below is not comprehensive.
In general, common themes in lobbying by these anti-trans groups include: stressing the need for preventing social transition; banning puberty blockers; and replacing trans youth healthcare with psychotherapy. Multiple submissions allege that existing trans health services are “captured” by “gender ideology”, calling for “watchful waiting” approaches and for “gender critical” clinicians to be prioritised in leadership. The Genspect conversion therapy advocacy network and its allies feature heavily within most anti-trans groups responding to the consultation.
Christian Concern is a prominent ultra-conservative evangelical pressure group, with a long track record of campaigning against legal rights to abortion, same sex marriage, what they call “transgenderism”, restrictions on conversion therapy, as well as demonising Islam and non-Christian immigrants, typically presenting all of these as a threat to Christian religious rights. In 2019 they claimed a mailing list distribution of 43,000 subscribers.
In their recommendations to readers about how to respond to the NHS interim specification consultation, they call on the NHS to replace current gender identity healthcare for young people with "[o]nly psychosocial and psychological support and intervention”. This is an approach the World Professional Association for Transgender Health (WPATH) and other expert bodies have described as “tantamount to ‘conversion’ or ‘reparative’ therapy under another name”.
Supporting this recommendation, CC cite Dr Paul McHugh of the noted religious extremist hate group ACPeds, and Professor Quentin Van Meter, a general board member of the pro-conversion therapy organisation IFTCC (as well as being a member of ACPeds).
Christian Concern continue to argue that childhood transition should not be allowed under any circumstances, that endocrinologists should be removed from the interim gender dysphoria service spec (so as to prevent the prescription of puberty blockers or cross sex hormones) and recommend that their followers request a “Watchful Waiting” approach.
Christian Concern also complain about NHS England’s continued participation in the Memorandum of Understanding on Conversion Therapy, citing Gender Critical psychotherapist Marcus Evans’ claims that this is interfering with his psychotherapy-only approach to treating gender dysphoria. Evans has been criticised and accused of promoting conversion therapy by local professional bodies while touring promoting his book in Poland (which Christian Concern cite in their guidance).
Additionally, Christian Concern criticise efforts to restrict referrals to the service to NHS professionals, suggesting this “creates not only a monopoly but a closed shop of mental health professionals entirely dependent on the state, and subservient to the [regulations against conversion therapy]”.
Our Duty are an anti-trans “gender critical” parent activist group who have a history of making violent threats towards NHS gender identity professionals, promote the work of conversion therapy advocate Quentin Van Meter, and are part of the Genspect conversion therapy advocacy network.
Much like Christian Concern’s guidance for responding to the consultation, Our Duty call for a removal of all endocrinologists from the service. They suggest that the only appropriate endocrinological intervention would be to “better align the patient’s body with the stereotypical morphology for their sex” — i.e. to chemically normalise them. While they recognise that it is unlikely that a young transgender person would actually want this sort of treatment pushing them further down a development pathway they are distressed by OD claim (without any medical evidence backing this assertion) that this might resolve their gender issues.
Our Duty further demand that clinical leadership roles should be held by an individual who is “Gender Critical”. They describe this as involving a belief that trans identity (which they call “transgenderism”) is a maladaptive coping mechanism spread contagiously through online misinformation. Our Duty also claim that new local services have to be built from scratch, as “[e]xisting services, particularly CAMHS have been ideologically captured by the gender identity movement”.
Other highlights include: calling for extending the age of adolescent treatment to 25 years old (a long running demand of OD’s to push back the rights of young adults over their healthcare); requesting that the service specification more actively discourage social affirmation; and demanding that services seek to “explicitly target desistance from transgender ideation as the desired outcome”. In other words, for NHS England to adopt a strong and explicit conversion therapy approach.
Transgender Trend are an anti-trans group who are allies with the Genspect network, and have previously taken part in events connected with figures involved in the IFTCC such as the endocrinologist Michael K Laidlaw. Transgender Trend celebrated the new draft interim service specification in their example post for supporters to respond to the guidance saying “NHS England has moved forward to a proper clinical care model”.
Similar to Christian Concern and Our Duty, Transgender Trend stress a “watchful waiting” approach. In common with Our Duty, they also call for guarantees that the clinical lead of any new gender identity service for young people “is not a ‘gender specialist’ who subscribes to ideological ‘gender identity’ beliefs, in denial of the material reality of sexed bodies.” This appears to be a demand for less expertise in the case of trans and gender diverse children, purely to reject the possibility that they may grow up to be trans adults.
With respect to the local service model proposed by the interim service specification, they call for a withdrawal from the MOU on conversion therapy “as long as it includes ‘gender identity’”, developing on Transgender Trend’s long running sympathies for gender identity conversion practices.
Transgender Trend claim that young people are being subjected to peer pressure to identify as transgender, and call for a complete stop on social transition, presenting a baseless claim that “teenage girls in particular… have been led to believe that medical transition will solve all their problems and have been coached online about what to say to the gender clinician in order to access hormones”. Throughout the example response they claim that a “gender affirmative” approach does not meet normal standards of care. Transgender Trend’s view is, of course, counter to global expert consensus within the transgender health field.
Anti-trans campaigning group Sex Matters have a track record of opposing the regulation of conversion therapy for trans people. In such discussions, they have explicitly linked to lobbying by other more extreme groups like Our Duty (among others). They are also allies with the Genspect conversion therapy advocacy network, which they describe as “seeking a rational approach to gender issues”.
Sex Matters have taken a more superficially professional approach to the consultation, including producing a glossily designed 25 page report for their official response. Despite its startling length, this document is much more careful to narrowly focus their consultation specifically on the subject of social transition, producing explicit answers only to Question 4 ”To what extent do you agree that the interim service specification provides sufficient clarity about approaches towards social transition?” and Question 7 ”To what extent do you agree that the Equality and Health Inequalities Impact Assessment reflects the potential impact on health inequalities which might arise as a result of the proposed changes?”.
The first of their responses raises a spurious claim that the service specification does not define “social transition” and therefore doctors are “being asked to make decisions about something for which they have no framework, and which they do not have the expertise to assess”. Social transition is a well established term for changes in haircut, clothing, name, pronouns and any other non-medical aspects of a gender transition a transgender person undergoes, documented as an important part of the gender incongruence assessment process by global trans health expert body WPATH. The suggestion that gender clinicians have no framework to assess or make decisions about this — a key term used routinely in their professional field — is laughable.
Like Transgender Trend (who’s response Sex Matters link to on their own site) and Our Duty, they claim that “social contagion” may be a factor in gender incongruence. However, going further, Sex Matters adopt another angle of attack on social transition. Sex Matters claim that social transition is potentially a threat to the rights of other students within schools, and that by validating social transition, the NHS is harming other children. They claim that through such action, social transition becomes “an attractor and goal for other children, exacerbating social contagion of gender dysphoria”.
Even more alarmingly they claim that parents and professionals are being subjected to “arguments that capitalise on exaggerated fear of self-harm and suicide”, and that “This will undermine the shifts recommended by Dr Cass”. In fact the interim Cass report itself cites clinical evidence of increased risk of self-harm and suicide, and only calls for further research to resolve questions some clinicians have as to whether distress is actually alleviated by interventions short of cross-sex hormones(p37). In its damning report on long waiting times at GIDS, the Care Quality Commission (CQC) also noted that “many of the young people waiting for or receiving a service were vulnerable and at risk of self-harm”. The downplaying of the serious mental health risks to young service users by Sex Matters is both callous and unprofessional, cynically misrepresenting the work of the Cass review.
The Society for Evidence Based Gender Medicine (SEGM) — an activist group against trans-affirming healthcare based in the United States (and part of the Genspect network) — has not published a consultation response if it has submitted one, but did publish a blog article celebrating the draft specification saying “The NHS Ends the "Gender-Affirmative Care Model" for Youth in England”.
Christian Medical Fellowship
The Christian Medical Fellowship is an evangelical organisation which campaigns for a conservative christian perspective on medical ethics issues, and heavily cites organisations from the Genspect conversion therapy advocacy network in its guidance including SEGM, Transgender Trend, Bayswater Support Group and Genspect’s “Stats for Gender” website. On their public Gender Identity resource sheet they directly link to ex-gay ministry “Living Out”.
The CMF have not published a full text of their responses to the consultation but like Sex Matters, they downplay the risk of suicidality among trans youth.
The Christian Institute
The Christian Institute are a fundamentalist Christian pressure group, with a long track record for opposition to same sex marriage. Since around 2018, they have escalated their backing of efforts to restrict “gender ideology” (recognition of trans identity) and inclusion in school settings, most recently collaborating with Gender Critical feminist groups.
In their two-page PDF response sheet providing example answers for supporters, they reiterate the institutional capture conspiracy theory. They demand “safeguards to ensure the new service is not also captured by radical gender ideology. They further suggest that if those who are current clinicians at GIDS are involved, “there is a risk that the new teams will be captured by the same ideology”. This is similar to many gender critical groups’ suggestions that existing expertise needs to be eliminated from gender identity services for young people.
They also explicitly call for the NHS to institute conversion therapy by default, saying the service should “strongly encourage social detransition for those referred to it who are already living as if they were the opposite sex”. They also call for an end to the use of puberty blockers, even under the research protocol proposed by the draft interim specification.
Their guidance cites Transgender Trend as evidence that puberty blockers cause persistence of gender dysphoria.
Although nominally ideologically distinct movements, Gender Critical lobbyists and conservative Christian groups share a lot of talking points in lobbying trans health services to cut back care for young people and replace it with varying degrees of conversion therapy.
While religious groups may be more straightforwardly recognisable and rejected by the health service as irrelevant to the care of young people, Gender Critical groups making the exact same often spurious points present themselves as secular, evidence based human rights groups concerned for the safeguarding of children.
Even the most moderate in tone and professionally polished lobbying efforts by anti trans groups suggest disregard for well-evidenced concerns for the mental health of young trans people, in terms of downplaying risks of self harm, with most of those investigated promoting gender identity conversion practices quite clearly.