Genspect’s Submission to the UK Department of Health and Social Care’s Consultation on Puberty Blockers

The UK Department of Health and Social Care (DHSC) has launched a targeted consultation on a proposed permanent order to prevent new patients under 18 from accessing puberty blockers through private prescribers. Below are Genspect’s answers to the consultation questions:

The Emergency Order:

To what extent do you agree or disagree with making the arrangements in the emergency order permanent?

• Strongly agree

Please explain your answer:

Genspect strongly supports making the emergency order permanent. The Cass Review found no high-quality evidence that puberty blockers improve outcomes for gender-distressed youth. Risks include low bone density, reduced neurocognitive ability, and disrupted sexual development. The Dutch Protocol, often cited to support puberty blocker use, was never designed for the current patient cohort and has been recklessly promoted. A permanent order aligns with growing international consensus, prioritizes safeguarding, and promotes non-medical approaches that address underlying issues often present in gender-distressed youth, including autism, ADHD, and same-sex attraction.

Positive Impacts:

In your experience, what have been the positive impacts of the emergency order?

1. Enhanced safeguarding: The order protects vulnerable youth from unnecessary medicalization, allowing exploration of underlying factors contributing to gender distress. This is particularly crucial for those with autism, ADHD, or other neurodevelopmental differences who may be overrepresented in this population.
2. Comprehensive care focus: Healthcare providers are encouraged to conduct thorough psychological assessments and offer non-invasive support. This holistic approach addresses complex factors including potential same-sex attraction, trauma, or mental health issues that may be driving gender distress.
3. Support for natural development: The order acknowledges the possibility of natural desistance in gender-distressed youth, preserving fertility and sexual function. It allows young people to explore their identities without the expectation of medical interventions.

Negative Impacts:

In your experience, what have been the negative impacts of the emergency order?

There have been no significant negative impacts of the emergency order. Some families may feel concerned about not being able to access puberty blockers, but this is often due to misunderstandings about the role and effectiveness of these treatments. This situation highlights the need for clearer education about the complexities of gender distress and the importance of providing well-rounded psychological support. While there is a possibility that some might seek unregulated sources for puberty blockers, this underscores the need for thoughtful communication about the risks of such treatments and the benefits of addressing underlying issues with appropriate psychological care.

Benefits:

In your experience, are there benefits in making the arrangements permanent?

• Yes

Please provide evidence to support your answer and explain how you think those benefits could be maximized:

Key benefits include:

1. Child protection: A permanent ban safeguards children from experimental treatments with unknown long-term effects. This aligns with the principle of “first, do no harm” and protects children’s right to an open future.
2. Evidence-based care promotion: The ban encourages non-invasive approaches addressing underlying issues such as autism, ADHD, trauma, or same-sex attraction. This recognizes the complexity of gender distress and promotes more comprehensive, individualized care.

To maximize benefits, implement healthcare professional training on non-medical approaches, develop clinical guidelines for psychological assessment, and create resources helping parents recognize appropriate identity exploration.

Risks:

In your experience, are there risks in making the arrangements permanent?

• No

Please provide evidence to support your answer and explain how you think those risks could be mitigated:

We don’t believe there are significant risks in making the arrangements permanent. To address concerns:

1. Ensure comprehensive care access: Clearly communicate that while puberty blockers are prohibited, robust psychological support remains available, including for co-occurring conditions.
2. Public education: Implement campaigns about the natural course of gender distress, high desistance rates, and the importance of exploring underlying factors. Promote understanding of gender non-conformity as a normal aspect of human diversity.

Impacts on Protected Groups:

Do you think the accompanying equality impact assessment (EQIA) appropriately reflects the potential impact on protected groups which might arise from the proposal to make the order permanent?

• Yes

Do you have any further comments or evidence about the potential impact on protected groups? If yes, please specify:

The EQIA correctly identifies that the policy primarily impacts vulnerable young people, including those with autism and mental health issues. While the policy disproportionately affects these groups, this is necessary to protect them from harmful, experimental treatments like puberty blockers. Given the lack of evidence supporting the long-term safety or benefits of these interventions, the priority must be safeguarding these children and ensuring they receive proper psychological support instead of unproven medical interventions.

Additional Evidence:

If you have any additional evidence (including clinical or patient feedback) you wish to provide, please outline it here:

Studies consistently show that a significant proportion of gender-distressed youth naturally align with their biological sex if given appropriate support without medical intervention. For example, research by Green et al. and Zucker from the 1980s found that most children with gender distress grew up to be same-sex attracted adults comfortable with their birth sex if not placed on a medical pathway.

Genspect’s work through initiatives like Beyond Trans and its support of Detrans Awareness Day underscores the importance of listening to the voices of those who have detransitioned. These individuals frequently report that underlying conditions such as autism, ADHD, and mental health challenges were overlooked before they were prescribed puberty blockers or cross-sex hormones. This further emphasizes the need for a cautious, holistic approach to care that prioritizes psychological support over unproven and potentially harmful interventions.

Data Gathering:

The government is keen to improve the data it gathers in relation to how many children and young people are affected by the order, as well as the impact of the information and guidance provided to them. If you have any thoughts on how this data could be gathered, please outline them here:

To gather comprehensive data:

1. Establish a detailed registry: Track all children referred for gender dysphoria, including non-medical interventions offered, co-occurring conditions (such as autism or ADHD), and long-term outcomes.
2. Implement standardized assessments: Use consistent tools across providers to ensure uniform data collection on mental health outcomes, social and psychological development, and the efficacy of non-medical support.
3. Long-term follow-up: Track outcomes into adulthood, including resolution of gender distress and overall well-being.

This approach will provide crucial insights into the effectiveness of non-medical support and inform best practices in supporting gender-distressed youth.