TL;DR: NHS England guidance has instructed GPs to refuse any care that supports under 18s to receive gender affirming care like puberty blockers and hormones. It also warns specifically against entering into shared care agreements with some of the UK Trans+ communities most used private health care providers of gender affirming care. It signals this approach could happen for adults too.
New classified NHS England guidance, obtained by the Good Law Project and seen by QueerAF, calls on doctors to refuse any care or support, like blood tests, that enable under 18s to continue using gender affirming care, including hormones and puberty blockers.
According to the Good Law Project, this guidance has been issued to all GPs. It reconfirms previous advice issued after the Cass Review to consider safeguarding referrals for parents who continue to support Trans+ children with gender affirming care after GPs refuse further support.
Strikingly, though the guidance explains this new information doesn't extend to adults, it provides advice on ways GPs can deny support to adults seeking the same kind of care using principles that have already become widely-used by GPs, leading to hundreds of trans adults across the UK losing access to gender affirming care - QueerAF
Advocacy group The Good Law Project obtained the document and has now shared it with QueerAF. We can confirm it tells GPs it "must refuse" to support the supply of GnRH analogues, known as puberty blockers, and further that it "should refuse" to support patients who get care from what it deems as "unregulated" providers of care that provide both puberty blockers and hormones. It considers any provider that does not operate in the UK, whether regulated in other countries or not, as unregulated.
Speaking to QueerAF, Jo Maugham, Executive director of the Good Law Project, says this guidance is a symptom of Wes Streeting bringing NHS England under his direct political control:
"The guidance will force GPs to actively cause risk and harm to trans people. Heroin addicts have their bloods monitored by their GPs to protect their health, but trans people, whose only 'sin' is to be trans, now cannot. I find it all quite sickening - for trans people, the NHS has become the national hate service."
How will this impact young trans people?
The prescribing of puberty blockers to minors was already banned by Wes Streeting earlier this year, but this guidance is an attempt to shut down already limited loopholes around the law.
It was common practice, even before the ban, for people taking hormones and puberty blockers they accessed through overseas providers to get blood tests from their local GP.
These tests help monitor key indicators like kidney function, so they can stay safe while using gender affirming care. This is common practice with many prescribed medications, including PrEP, cancer care and immunosuppressants.
This new guidance will prevent under 18s from getting this kind of support from GPs. The guidance issues advise against engaging in what are known as ‘shared care agreements’ with "unregulated" providers of hormone medication. Shared care agreements allow patients to obtain a written agreement between a patient, their general practitioner (GP), and another doctor so the GP can provide elements of their care.
How will it affect parents?
The guidance sets out what GPs should do if they decide to discontinue an existing shared care agreement, including advising against the continued use of gender affirming care, informing the family in writing that they are unregulated.
However, building on a practice that had already become part of the picture, it advises that "safeguarding measures should be considered where the administration of a medicine from an unregulated source presents an immediate safety risk." This increases the already existing risk that parents may get a safeguarding referral if they continue to support their Trans+ child's care - QueerAF
The private care providers who will be worst affected
Two private healthcare providers are named in the guidance, drawing a target on their back. Extensive details about GenderGP and Anne Healthcare have been provided to GPs.
GenderGP has been at the centre of intense scrutiny by both medical bodies and the press after one of its founders, Dr Helen Webberley, was suspended for her work with a young transgender teenager. This was later overruled, and the company has since moved its operations overseas - BBC
The guidance also names a newer start-up, Anne Healthcare Ltd, which, though registered in the UK, is not registered with the Care Quality Commission.
Including both organisations in the document could have a vast impact for patients who are seeking new or have existing shared care agreements in place with the organisations if GPs follow the new guidance.
What does it say about adults?
The advice "does not extend to adult patients". However, it also states that "unregulated healthcare services pose a potential risk to patient safety across all age ranges".
It says NHS England plans to address the management of adults who source medications outside of the “NHS-commissioned gender dysphoria service” by the end of 2026, and as early as this year.
It then sets out advice that many GPs have already been using to deny adult care - including those who have been through the medicalised gender identity service process. It explains that:
"A GP may decline to accept responsibility for prescribing, monitoring and testing if the GP is not assured that the provider offers a safe service, or is not assured that the request has been made by an appropriate gender specialist as long as the GP is also satisfied that declining responsibility would not pose a significant clinical risk to the individual."
Analysis: A building block for restrictions to adults
The Health Secretary this week said he was "genuinely sorry" for "fear and anxiety" caused by the puberty blocker ban. If those comments were designed to assuage the community that there was a positive plan in place, this week's NHS Guidance will erase what little - if any - confidence the Trans+ community had left in the health secretary.
It is especially striking that this document sets out that NHS England plans to review how this all applies to adults. It’s too early to be conclusive on this, but if you connect the dots in this guidance - which casts extreme doubt over the future of support for trans people "of any age" receiving care from private prescribers of care - it is clear where the NHS is headed under Streeting's control.
Indeed, with only a handful of providers of this kind of care in the UK for adults considered ‘regulated’ by this document - and none for people under the age of 16 - this guidance makes an already challenging space practically impossible to navigate. If the guidance on refusing shared care to children extends to adults, it will have an extensive effect because while it is possible to get blood tests, and similar support outside of the UK, it is difficult and costly.
For now, if this guidance is implemented by GPs, young vulnerable Trans+ children will be left in limbo, and their parents will be put further at risk of being penalised for trying to support their family to live a happy, safe life.
NHS England did not respond to our request for comment in time for the article’s publication but did confirm receipt of it.
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