Summary Statement
- At CHG we are committed to providing safe and evidence-based care.
- We do not take over prescribing of gender-affirming hormones from private clinics.
This follows guidance from the RCGP (Royal College of General Practitioners) and
GMC (General Medical Council). - If you would like assessment or treatment, we will refer you to an NHS Gender
Identity Clinic (GIC). These clinics provide safe, specialist care with proper checks
and follow up. - We may consider shared care prescribing if:
The request comes from an NHS specialist service, and
The treatment is safe and within the competence of our GPs - GPs are not required to prescribe medicines that are outside their training,
experience or safety standards.
Policy in Full: Gender Hormone Prescribing Policy
Cirencester Health Group is supportive of patients seeking or receiving care for gender
related matters. We are committed to providing safe, consistent, and evidence-based
care for all patients. We are happy to discuss issues and make referrals within the
NHS and to advise of referral to the private sector for assessment and treatment. Our
duty as NHS GPs is to prescribe only within our professional competence and in line
with national guidance.
Policy Objective
To ensure the safe and effective management of transgender patients requiring
hormone therapy through shared care agreements. This policy outlines the criteria that CHG will consider shared care prescribing responsibilities.
Scope
This policy applies to all healthcare providers and transgender patients seeking
shared care prescribing services within the practice.
Overview
Hormonal treatments for gender incongruence require expert oversight, which is
beyond the scope of NHS GPs’ training and expertise.
As NHS GPs, we are very happy to work with NHS gender identity clinics when a
shared care arrangement is in place and appropriate assessments have been
conducted. However, we are unable to prescribe hormone treatments for gender
incongruence unless they are part of a formal NHS shared care protocol. This includes
requests from private practitioners and requests for ‘bridging’ prescriptions.
Patients are strongly advised to avoid obtaining hormone medications from online
sources without appropriate specialist guidance. Patients may choose to seek care
from private providers, but the practice will not assume the responsibility of prescribing on behalf of private clinics.
Context and Rationale
Our practice is dedicated to delivering the highest standard of primary care to all
patients, including those who are transgender and dealing with gender incongruence,
also referred to as gender dysphoria. We understand that transgender patients often
face challenges that GPs are well-placed to assist with, both in terms of physical and
mental health, as well as offering guidance or referrals to specialised services.
Unfortunately, gender identity clinics in the UK are overwhelmed with demand,
resulting in long waiting times. These clinics play a crucial role in coordinating detailed
psychological assessments required before starting medical treatments, including
hormones and surgeries.
Consequently, GPs are encountering requests for ‘bridging’ prescriptions while they
await formal assessment, particularly those who have already begun selfadministering medication or have sourced drugs online. We understand the frustration
many patients feel due to these delays, but it is essential to practice medicine safely
and responsibly.
Hormonal treatments for gender incongruence are used outside of their licensed
indications in the UK and require ongoing monitoring from specialist gender physicians or endocrinologists. These medications can have irreversible side effects, including changes to physical traits, fertility issues, and an increased risk of conditions like breast cancer and blood clots. As registered medical professionals governed by the General Medical Council (GMC), we must adhere to the principles of GMC Good Medical Practice. Article 14 of the GMC’s guidance emphasises that doctors must work within their areas of competence.
According to GMC guidelines, prescribing medications outside their licensed
indications should only occur if the doctor is confident in their ability to manage the
medication and counsel the patient thoroughly on potential risks and side effects.
Furthermore, the GMC’s ‘Trans Healthcare: Ethical Guidance 2019’ defines an
experienced gender specialist as ‘a physician with specialized training and at least two
years of experience in a gender dysphoria practice, such as those within NHS Gender
Identity Clinics.’
The Royal College of General Practitioners (RCGP) has published a statement about
GP competences to prescribe hormones for gender incongruence including the topic
of ‘bridging’ prescriptions.
Read the statement on the Royal College of General Practitioners website
Our approach at CHG: As GPs, we are more than happy to discuss treatment options and offer support to individual patients. If a patient is interested in pursuing medical (hormonal) or surgical treatments, we can facilitate initial discussions and make referrals to the relevant NHS gender identity clinics.
Once a patient has been assessed by an NHS gender identity clinic, CHG is open to
discussing the possibility of continuing hormone treatment, provided that a formal
‘Shared Care Protocol’ is in place. This protocol, produced by the specialist clinic, will
outline the monitoring requirements and responsibilities of patient, specialist and GP.
If the protocol is followed and safety measures are in place, we will be happy to assist
in prescribing treatments under the guidance of the specialist, with the added
safeguard of additional NHS gender specialist reviews should any complications or
side effects arise.
Prescribing hormones outside of a rigorous ‘Shared Care Protocol’ would be outside
of our competence as GPs. This applies to where patients may be sourcing treatment
themselves from the internet, from private providers and requests for unsupervised
‘bridging’ prescriptions. It is outside of our expertise and competence to prescribe
hormones for gender incongruence where proper assessments and care agreements
are not in place.
CHG position regarding self-sourced or private prescriptions
CHG strongly discourages patients from obtaining prescriptions for hormones via
online channels without first receiving specialist medical advice and
assessment. Medicines bought online are likely to be unregulated and may be
contaminated and dangerous.
We recognise that as a result of long NHS waiting times, people are seeking private
treatment often through on-line providers. Patients who opt for assessments with
private healthcare providers are free to do so at their own risk, expense, and discretion.
CHG will not take on prescribing responsibilities for patients treated privately. In line
with the RCGP and GMC guidance, we do not enter into shared care prescribing
agreements with private clinics for gender-affirming hormone therapy. This decision is
based on concerns about regulation, safety, and the need for proper monitoring.
Patients who choose to continue treatment privately will need to arrange their
prescriptions and monitoring directly through their private provider.
NHS Shared Protocol Considerations
Requests for shared care prescribing will only be considered when the request comes
from an NHS specialist service. These requests will be reviewed on a case-by-case
basis, taking into account:
- The type of medication requested
- Safety and monitoring requirements and arrangements
- The competence and experience of the GP being asked to prescribe
Please note, GPs are not obliged to accept prescribing responsibilities if the treatment is outside their professional competence, or if concerns exist about the quality or safety of care arrangements.
Provider requirements
- The provider must be registered with the Care Quality Commission (CQC) and
adhere to its standards for safe, effective, compassionate, and high-quality care. - The provider must be led by a current GMC registered Consultant with relevant
expertise in transgender healthcare, including endocrinology, gender dysphoria, or another appropriate specialty. - The consultant must have direct responsibility for the patient’s care plan and
medication recommendations. Treatment provided by private providers must align
with NHS treatment guidelines.
Monitoring & review
- Providers must supply a detailed care plan, including medication regimen,
monitoring requirements, and any anticipated changes. The care plan must specify
the shared responsibilities between the provider and the GP practice. - Providers must be readily available to offer guidance and support to the GP
practice regarding the management of the patient’s care (even after discharge).
Any clinical concerns or complications must be addressed promptly by the provider.
Responsibilities
Provider
- Provide expert-led, comprehensive care and oversight of the patient’s treatment.
- Maintain CQC registration and adhere to its standards.
- Respond promptly to requests for information or support from the GP practice.
GP Practice: - Ensure safe prescribing practices within the scope of the shared care agreement.
- Conduct regular patient reviews in line with the care plan.
- Communicate with the provider regarding any deviations, side effects, or clinical
concerns.
Patient: - To have an agreed understanding of this transgender policy and the shared care
policy provided by the gender services. - To engage with the appropriate medication monitoring and requirements set out
by the shared care policy.
Clinical Governance
- This policy is based on GMC Good Practice in Prescribing and Managing Medicines
and Devices and the RCGP guidance on the role of GPs in transgender care.
Prescribing decisions are made with patient safety as the highest priority. An internal review of prescribing requests and decisions will be carried out to ensure the policy is applied consistently. - All patients will be treated with respect, dignity, and sensitivity. Where a prescribing request is declined, patients will be given a clear explanation and information about available NHS options.
Communication & Training
This policy will be communicated to all staff involved in prescribing and managing
shared care arrangements. Regular training sessions will be held to ensure
understanding and compliance. It will be available to review on the Practice Index
policy library.
Policy Review
This policy will be reviewed every two years or sooner if regulatory, clinical, or service
delivery changes occur.
Further Information
- Visit the Gendered Intelligence website – You can access direct help and
information from Gendered Intelligence, a charity that supports patients waiting
for treatment. - Download the PrEP Patient Information Leaflet
- Visit the Yuno Sexual Health website for sexual health services in Bristol
- How to find an NHS gender dysphoria clinic – NHS (www.nhs.uk)