Last month, I shared examples of letters that the National Gender Service (NGS) has been sending to GPs, advising them not to provide their trans patients with blood tests to monitor their hormones. It argued this course of action on the basis that there are no risks associated with blood hormone concentrations.
This was contradicted by the NGS’s own internal policies, before even considering the need to ensure optimal dosing effectiveness, following the instructions of a patient’s own medical team, or international best practice guidelines.
In addition, these letters from the NGS usually allege that GenderGP, an international trans telemedicine service with a multidisciplinary team who follow international best practices, are contravening current Irish Medical Council (IMC) guidelines:
Some letters provide more detail on the supposed violation:
There is similar to responses made by Dr. Karl Neff to TDs in relation to a parliamentary question regarding clinical practices at the NGS. This is a topic that was also touched on in David Monaghan’s article for the Dublin InQuirer which I’d like to dig into more.
Section 43 is on Telemedicine, and the relevant section is 43.2:
It is the best kind of correct to say that GenderGP doesn’t have any prescribers registered with the IMC, that it only offers online consultations, and that it is unregulated in Ireland. To understand why this is technically correct, but not the full story, you could ask the IMC.
While researching his article, Monaghan queried the IMC on this and was kind enough to share their response. After pointing to the relevant guidelines the IMC says:
This takes a bit to understand. EU Directive 2011/24, also known as the Cross-Border Directive, covers patients’ rights to access healthcare in other EU countries. The relevant bit here is Article 3 (d). In Ireland this was implemented in the EU (Application of Patient Rights in Cross Border Healthcare) (Amendment) Regulations 2015 section 6. The Irish Medical Council summarises this in their second paragraph, namely that an EU doctor providing telemedicine across countries only needs to follow the rules of the country in which the doctor is based — not the country of the patient.
The third paragraph clarifies further that an EU doctor providing telemedicine doesn’t need to register with the IMC. And adds that if you wish to complain about a doctor that you’ll need to do so to the equivalent of the IMC in that doctor’s country. Which is to say the appropriate regulation is covered by another EU country.
Now I must mention that the IMC has an updated 9th edition of their guidelines which will come into effect from 1 January, 2024. Section 43.2 is now covered by 60.6, which makes all of this a little bit clearer:
Given that GenderGP’s prescribers are EU doctors working via telemedicine, they are not contravening either the current or upcoming IMC guidelines.
I’m sure that once the NGS learns that they’ve been providing incorrect information in their letters to GPs that they’ll rush to correct their error, and inform all the GPs they’ve previously contacted. After all, in the words of Dr. Neff earlier this year speaking on Newstalk about these Medical Council guidelines “we give them [GPs] the best clinical advice possible and that we give them honest advice”.
No longer will trans people who are denied simple blood tests by their GPs have to consult the secret list of good GPs that the community maintains, hoping one of them is both nearby and taking on new patients.
Jes Black (she/it) can tell that Dr. Blåhaj (she/her) is a modern doctor. Using digital scales when she cosplays Lady Justice is merely one sign.
