• The Practice completed an incorrect referral to the adult gender identify service in July 2022 • The Practice are responsible for introducing him to the testosterone replacement therapy, when they completed an initial blood test in October 2022 • The Practice would not monitor his blood, as a result of their testosterone use which began in October 2022
20. The law says a person needs to make their complaint to us within a year of becoming aware of the problem. We cannot investigate complaints brought to us after one year, unless we consider there is a good reason to do so. We have discussed this with Mrs B, Mr G’s mother and representative, to understand the reasons why they could not do so. We have also considered the time the organisation has taken to respond to Mrs B.
21. Mr G first became aware of his concerns in about the incorrect referral in November 2022. He said he also became aware of the issues with the blood tests and monitoring at around the same time. Mr G’s mother, Mrs B brought the complaint to us in April 2025.
22. At this time, these parts of the complaint were one year and five months out of time.
23. During our communication with Mrs B, we asked why there was a delay in bringing the complaint to us. She told us that she was not aware she could bring a complaint to us, until after she made a complaint about her own care in late 2023. She said she then complained about Mr G’s care and treatment, on Mr G’s behalf, in April 2024. The complaint was already five months out of time, when Mrs B complained to the Practice.
24. Mrs B has not provided any further details as to why she did not bring the complaint to us sooner.
25. The Practice said it had communicated with Mrs B with concerns about Mr G’s care on 9 March 2023, 21 April, 12 July, and 22 March 2024. These dates were before Mrs B contacted the Integrated Care Board (ICB) about the Practice. She then returned to the Practice with concerns in August and October.
26. We recognise Mr G has concerns about his gender care and wishes to receive support from his GP. We acknowledge that not being about to access GP support will have made the process difficult for him.
27. We have seen no strong evidence to be able to put our time consideration to one side. We believe that Mr G and his mother, Mrs B could have brought their complaint to us sooner.
the Practice would not enter into a shared care agreement with Gender Plus in 2024.
28. Before we decide if we should conduct a detailed investigation of a complaint, we look at whether there are signs the organisation has got something wrong. We do this by comparing what should have happened with what did happen. We have done this and have not found any indications that something has gone wrong.
29. Mrs B told us they want the Practice to enter into a shared care agreement with Gender Plus to monitor Mr G’s bloods and support his gender care. Gender Plus is a private gender and mental health service, supporting the UK and Ireland.
30. The Practice said it has discussed Mr G’s case with Nottingham and Nottinghamshire integrated Care Board (ICB). It has requested information from Gender Plus and reviewed this in line with guidance for general practice.
31. The ICB told the Practice that a shared care agreement can be entered into with a private practice, if they are providing a commissioned NHS service.
32. The Practice said that as Gender Plus are not providing a commissioned NHS service it is under no obligation to provide an NHS prescription, based on the recommendation of a private specialist.
33. Additionally, the Practice has also referred to the Cass Review, ‘Independent review of gender identity services for children and young people, final report’, April 2024 which says GPs should not be expected to enter into shared care agreements with a private provider.
34. GMC Good medical practice, Section 1.7d says doctors should propose, provide or prescribe drugs or treatment (including repeat prescriptions) only when they have adequate knowledge of the patient’s health and are satisfied the drugs or treatment will meet their needs.
35. BMA guidance also says if a GP does not feel competent to prescribe the requested medication, or they do not know if the medication best serves the patient’s needs, the GP should inform the private provider that the prescription should be provided by a specialist.
36. Additionally, BMA guidance also highlights that shared care with private providers is not recommended due to the general NHS constitution principle of keeping as clear a separation as possible between private and NHS care. All shared care agreements are voluntary, and practices can decline share care requests on clinical and capacity grounds. The responsibility for the patient’s care and ongoing prescribing then remains the responsibility of the private provider.
37. From what we have seen, we believe the Practice is acting in line with the GMC and BMA guidance, as Gender Plus is not providing Mr G with an NHS commissioned service.
38. We understand that Mr G and his family are disappointed by the Practice’s decision. We recognise the distress and financial impact this has had.
39. We understand how difficult it is to make a complaint. We thank Mr G and his family for bringing their concerns to us, and hope we have explained our decision clearly.