HIS Standards for Gender Identity Healthcare Services
Published: 14/02/24
Healthcare Improvement Scotland (HIS) are consulting on their draft standards for gender identity healthcare services for adults and young people
Although community pharmacies and primary care services are mentioned throughout the draft standards, our members are clearly not gender identity healthcare services and HIS do not regulate our sector’s day to day business. However, feedback from our members suggests that responding to this consultation would be worthwhile, in the main to highlight some of the challenges that are being faced in practice.
The consultation documents can be found here, with our response laid out below.
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Yes.
We support this right for all people and patients accessing healthcare services in Scotland. We champion free and equitable access to community pharmacy services, but are aware that there are some specific challenges in practice for marginalised groups of patients and professionals alike. This is particularly the case where there are sex-specific service offerings, for example contraceptive services and consultations for suspected urinary tract infections. For safe and effective services to be delivered, healthcare professionals must understand the patient’s physiology to arrive at the most safe and effective course of action with the patient – and this will require the patient to share detail that may make them feel uncomfortable.
The standards must reflect this, and provide guidance for healthcare teams on how to build a therapeutic partnership with the patient, being respectful of their preferences whilst being clear that their access to services may be determined by their birth sex as opposed to chosen gender identity.
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No
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Yes.
We have had feedback from our members and their teams that, where timely access to NHS services is not available, this can result in people (particularly those who are younger) accessing private and online services that can be of questionable quality, offering access to treatments with very limited interaction between professional and patient. Community pharmacy teams have a responsibility to safeguard all patients, which can be challenging when there is limited information available to them and sometimes the first interaction with a person can be on the presentation of a prescription from an unknown prescriber (who can be based overseas). The pharmacist on duty can be caught in a very difficult position, having to choose whether they:
a) make a supply when unsure whether the person has had appropriate support in their journey to date or whether the standards expected of gender identity healthcare services have been met. There is often concern that without confidence in the service delivered by the private gender identity service, making a supply could be harmful in the longer term than redirecting to a more reputable source of support e.g. an NHS service.
or;
b) Do not make a supply – understanding that this decision may be just as or even more harmful than making a supply against the backdrop of uncertainty that use of private and overseas services bring.
Even more distressing than being faced with this choice is that our members fear that they are perceived as making a values or belief-based decision when they are in fact trying to support the person at the centre of the episode of care. The patient-facing end of guidance needs to recognise that whilst we would all seek to create and maintain seamless pathways of care, sometimes there are necessary and unavoidable bumps in the road when services are not well integrated.
Our members require that trusted NHS services provide timely access to care. We also require that the delivery of these standards are required of both UK private services and organisations from outwith the UK which offer services to UK patients. We would suggest some form of assessment/accreditation to this end.
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Yes.
Clear referral routes into services for pharmacy teams would be of great use, particularly in the scenarios described in our answer to question 3.
Also in relation to our answer to question 3, we would encourage HIS to ensure that this standard in particular is applied in practice to the regulation of private organisations delivering services into Scotland.
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Yes.
Those involved in the dispensing of prescriptions for people accessing gender identity healthcare would appreciate access to training and CPD materials on gender identity and how they can support more equitable access to care in general. However, there is a challenge in that there is no mechanism available to make this training mandatory.
As raised in our answer to question 1, support in how to respectfully make clear the boundaries and terms of sex-dependent services would also be appreciated.
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No.
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Yes.
Please see our answer to question 3.
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No.
This consultation seeks views on the proposal to make a permanent order to come into force when the second emergency order to prevent new patients aged under 18 from beginning to take puberty blockers for the purposes of gender incongruence and/or gender dysphoria, under the care of private prescribers expires.