Women Speak Tasmania have co-signed this letter to Federal Health Minister Greg Hunt, asking for a national Inquiry into guidelines for treatment of children with gender dysphoria
Dear Minister Hunt
Re: Inquiry into clinical treatment of gender dysphoria in children and adolescents
Enclosed with this letter please find suggested Terms Of Reference in respect of the above inquiry.
We note your office communicated with the Royal Australasian College of Physicians (RACP) on 16 August 2019 requesting they –
‘urgently consider and advise on the clinical best practice for the treatment of gender dysphoria in children and adolescents.’
You said –
‘It is important that we have a nationally consistent standard of care that is evidence based and with appropriate safeguards to protect the interests of the patient.’
We agree entirely with the rationale informing your request for an inquiry.
With respect, however, we strongly recommend that any inquiry into the clinical protocols, including medical and surgical interventions, currently provided to children and adolescents presenting at gender services in Australia should be undertaken by an independent third party capable of assessing the quality of the evidence base used to guide those protocols.
While physician groups (such as the RACP) may have experience in the provision of various interventions, including the prescription of hormones, if used, to delay puberty and/or promote secondary sex characteristics of the transitioned sex, they are not necessarily expert analysts of scientific research in the area of transgender health care.
Such analytical services are provided by organisations such as Cochrane in the USA and the Oxford University Centre for Evidence Based Medicine in the UK.
Given the available evidence of a significant increase in the number of children and young people, particularly females, presenting at Australian gender services in the past five years, it is vital that all aspects of the clinical approach to these young people be thoroughly investigated.
It is acknowledged, for example, by clinicians and researchers in the area of transgender health care that the long term effects of puberty blocking hormones and cross-sex hormone administration are unknown in otherwise healthy individuals. Similarly, the long term psychological impacts of re-assignment surgery, and the infertility that is a likely consequence of hormonal interventions for children and young people, have not been documented to date.
Clearly, more research in this area is needed, as is a comprehensive review of any existing studies.
A properly constituted third party inquiry could also examine any cultural and sociological factors influencing the expanding cohort of children and young people requesting gender services, as well as the relevance of socio-economic circumstances and any co-morbid mental health diagnoses.
Legal issues pertaining to the ability of minors to consent to medical and surgical interventions with known permanent consequences are an additional, crucial consideration.
We note that in April this year, the Swedish National Council on Medical Ethics (Smer) wrote to the Ministry of Health and Social Affairs calling for a comprehensive investigation into the scientific bases guiding transgender health care for children and young people and the off-label prescription of puberty blockers and cross-sex hormones for these groups, together with an evaluation and update of current guidelines.
The announcement by Smer came shortly after the airing on Swedish television of a documentary program, ‘The Trans Train’, that interrogated the phenomenal increase in adolescent girls and young women seeking gender services.
The Council recommended these matters be reviewed by three separate committees to ensure broad ranging coverage of the issues.
We suggest the Australian inquiry into transgender health care for children and adolescents should be similarly meticulous, conducted by experts in the evaluation of research, well-informed and thoroughly transparent.
We look forward to your response.
Kind regards
Dr Dianna Kenny – Psychologist
Dr Geoff Holloway – Sociologist
Judith Hunter – parent of ROGD adolescent
John Hersee – parent of ROGD adolescent
Susan Barley – Australian Parents Questioning Gender
Dean Charles Tavares – The Phase, Detransitioner Support Network
Anna Kerr – Principal Solicitor, Feminist Legal Clinic
Joanna Pinkiewicz – Teacher
Isla MacGregor – Advocate
Bronwyn Williams – Retired Solicitor/Social Worker
Terms of Reference for Inquiry
Inquiry into gender dysphoria and its treatment in children and adolescents
Draft Terms of Reference
Preamble
The Hon. Greg Hunt MP, Minister for Health, recently announced an ‘inquiry’ into gender dysphoria and its treatment in children and adolescents.
There were no terms of reference or timeline in Minister Hunt’s letter to the Royal Australasian College of Physicians, which has been charged with undertaking the inquiry.
We therefore propose a series of issues to be addressed in the inquiry.
We further recommend that submissions on this very important issue be sought from both overseas and Australian experts in the medical and psychological treatment of children, both generally and specifically in the area of gender dysphoria.
We suggest the following as a guide to the terms of reference –
1. An examination of the adequacy, effectiveness and impact of current policies, practices, legislation and regulation governing the identification, diagnosis, provision of medical and surgical interventions, and social integration of children and young people in relation to gender dysphoria, having regard to, inter alia:
a) analysis of the psychological, sociological and cultural causation or aetiology of gender dysphoria;
b) the current and historic prevalence of gender dysphoria amongst
children and young people;
c) the rationale and evidence underpinning current policies and practices in transgender health care in Australia, and any alternative approaches. In particular –
(i) the evidence base relied on by Australian gender services;
(ii) client record keeping and follow-up protocols, including numbers lost to follow-up;
(iii) demographic analysis of children and young people presenting at gender services – age, natal sex, level of educational attainment and socio-economic factors
(iv) rates of comorbid mental health diagnoses in children and adolescents presenting at gender services, and evidence of clinically appropriate consideration of these diagnoses prior to recommendation of medical and/or surgical interventions;
(v) rates of comorbid neurodevelopmental and cognitive diagnoses, for example, Autism Spectrum Disorder, in children and adolescents presenting at gender services;
(vi) evidence of thorough evaluation and consideration of differential diagnoses for children and adolescents presenting at gender services;
(vii) evidence of counselling in relation to the risk and benefits associated with medical/hormonal and surgical interventions for children and adolescents presenting at gender services. In particular, evidence of competence to consent to treatment which will likely impair long term fertility;
(viii) level of access to appropriate, comprehensive mental health services generally;
(ix) evaluation of service protocols to assess the role of potential suicide risk in determining the recommendation of medical and/or surgical interventions for children and adolescents presenting at gender services, given the role of such interventions in ameliorating long term suicide risk is not known;
(x) documentation of complications and adverse side effects arising from medical (puberty blockers and cross-sex hormones) and surgical interventions;
(xi) documentation of clients requesting assistance with de-transition
d) examination of the funding and sponsorship provided to enable formulation and publication of the Australian Standards of Care and Treatment Guidelines for Trans and Gender Diverse Children and Adolescents. In particular –
(i) relationships, if any, between the authors and pharmaceutical companies; and
(ii) the contribution of groups representing transgender people to the guidelines
e) international trends, research and scientific studies concerning the impact of any prescribed medical and/or surgical interventions;
f) analysis and comparison of legislative environments and models of care for Australian state and territory jurisdictions and overseas jurisdictions;
g) any other related matters.
2. Any changes the inquiry thinks desirable to the functions and procedures of government oversight and regulation arising from the investigation of the matters above.