Thu 28 Mar 2024 — 4 min

Trans Safety Network express our deep concerns about the transparency and integrity of the 2020 NICE evidence reviews into puberty blockers and gender affirming hormone therapy, as well as the NHS Gender Dysphoria working group which commissioned them.

In June of 2023 it was disclosed to us by members of the Cass Review team that anti-trans author and commentator Dr Az Hakeem was part of “NHS England’s policy working group which commissioned the NICE evidence reviews undertaken in 2020”. Dr Az Hakeem has long been a partisan opponent of gender affirming medical treatments. While Hakeem disavows conversion therapy or trying to dissuade trans people from medical interventions, on his personal website he directs readers looking for specialist support for gender dysphoria to conversion therapy activist groups, such as Bayswater Support Group, and the anti-trans pseudoscientific lobby group SEGM. Hakeem is also a member of CAN-SG who have from their earliest webinars (link) promoted the idea that trans people should be dissuaded from transition and instead either change their minds, or undergo therapy to live with the discomfort of gender dysphoria without accepting their trans identity — in other words, that trans people should undergo conversion therapy.

We note, with concern, that two other members of the anti-trans lobby group SEGM, Richard Byng and a Mr Richard Stephens, were in 2022 cited in a meeting with the United States government as being members of the NHS England Working Group on Gender Dysphoria.

As part of the working group that commissioned the NICE reviews, Hakeem (and potentially other activists against trans healthcare) will have been involved establishing the parameters for the research questions being asked. In particular they may likely have had some influence in determining the acceptance criteria for evidence falling within the remit for the NICE reviews, meaning the ability to rule out evidence which is potentially inconvenient to his existing biases. As the NICE reviews were retrospective, reviewing historic research, this will have been an unparalleled opportunity for a staunch campaigner against trans healthcare to fix the criteria ahead of a strategic piece of research.

The NICE reviews have been controversial - primarily because they elected in their approach to exclude numerous pieces of published clinical research around puberty blockers and gender affirming hormone treatments which address the specific concerns it sets out to answer. The reviews also then heavily criticise the quality of the small quantity they did opt to review while making only a passing recognition of long running concerns that high quality controlled studies are not ethically practicable. Lower quality indicative evidence is routinely accepted in many areas of medical practice out of ethical necessity — experimentally choosing not to treat some patients when existing evidence indicates a course of treatment is likely to be beneficial is fraught with ethical challenges.

Freedom of Information Requests seeking to understand better how this research was shaped and what sorts of conflicts of interest may have been involved have been refused. In effect this hampers public understanding of a contentious piece of public interest research from those seeking to understand the results. It is only by chance that Trans Safety Network came into possession of this information via a third party.

In the interests of open science, transparency and accountability, we call on NICE, NHS England, and The Cass Review, to open up to the public those details which would allow public scrutiny of potential conflicts of interest in driving Gender Dysphoria health policy in England.