A practice in the West Oxfordshire area

3. Mx V complains since March 2022 the Practice refused to prescribe hormone therapy treatment they needed for gender dysphoria that had been recommended as appropriate by the Gender Identity Clinic (GIC) in 2021.

4. Mx V also complains about the length of time it took for NHS England to respond to the complaint.

5. Mx V says as a result they had to seek expensive private prescriptions to start their physical transition. The additional stress of waiting to access NHS treatment, after already having waited from 2018 to 2021 for a diagnosis and treatment plan has been extremely difficult.

6.They say they have suffered increased suicidal ideation, felt increasingly isolated, had thoughts of self-harm and a profound loss of self-worth around their gender identity. They say this has been a contributing factor to being diagnosed with social anxiety disorder in 2023, which eventually led them to resigning from their job in 2024 as they could no longer cope.

7. They say it increased financial problems due to having to seek private treatment and their trust in fair and reasonable treatment through other aspects of NHS healthcare has greatly suffered, due to years of their health needs being ignored or dismissed.

8. As a result of bringing this complaint to us, Mx V is seeking an apology, service improvements and financial remedy of £1500.

9. Mx V has been under care of consultants at their local Gender Identity clinic (GIC) after first being referred there in 2018.

10. They received a diagnosis of gender dysphoria in September 2021. An individual care plan was agreed in September 2021, and they were due to be referred by a GP to a specialist service to start Testosterone hormone therapy.

11. Mx V says their GP then informed them this specialist Endocrinology department was not taking referrals as the service was closed due to medicine licensing issues and then funding disagreements and closed to patients by early 2022.

12. Their GP did not feel able to agree to a shared care agreement with Northamptonshire Gender Identity Clinic due to the uncertainty over provision for testosterone hormone therapy within Oxfordshire. Mx V says they were then left with no alternative but to seek expensive private prescriptions from March 2022 to start their physical transition.

13. Mx V initially complained to the ICB on 16 August 2022, who referred the complaint on to NHS England to respond.

14. NHS England sent its response on 30 October 2025, and Mx V brought the complaint to us the same month.

Prescription of hormone therapy treatment

17. 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.

18. Mx V says their GP refused to prescribe the hormone therapy treatment they needed for gender dysphoria and that had been recommended as appropriate by the Gender Identity Clinic (GIC) in September 2021. They say this was from March 2022 onwards and due to the absence of a shared care agreement between Berkshire, Oxfordshire and Buckinghamshire (ICB) and the GIC.

19. Mx V explains that the long wait for NHS treatment forced them to seek costly private prescriptions to start their physical transition. The stress of waiting, after already waiting years for a diagnosis and treatment was extremely difficult. They say this caused increased suicidal thoughts, self-harm thoughts, feelings of isolation, and a loss of self-worth connected to their gender identity. They believe this contributed to their diagnosis of social anxiety disorder in 2023, which eventually led them to resign from their job in 2024 as they could no longer cope.

20. Additionally, they say the expense of private treatment worsened their financial problems, and they have lost trust in the NHS after years of feeling their health needs were ignored or dismissed.

21. The NHS England’s complaint response letter says the GP Practice was and is unable to prescribe hormone therapy treatment due to the absence of a Shared Care Agreement between the local Integrated Care Board (ICB) and the Gender Identity Clinic (GIC). It says the GIC has indicated it cannot provide any monitoring or advice regarding the hormone treatment, as the responsibility for ensuring safe and effective treatment rests with the prescribing body. However, they are happy to take over monitoring and offer support for hormone treatment, if local resources are available from the ICB.

22. It goes on to say the ICB do not commission this service meaning it is currently unavailable. It says without formal commissioning and a Shared Care Agreement, it is unable to provide the necessary support or resources related to this service.

23. The records show the Practice referred Mx V to the GIC in June 2021 but the clinic did not have a contract to prescribe and monitor hormone treatment so the GP wrote to the endocrinology service who replied saying it could not support as this was a specialist area for which it did not have a contract. Following this, Mx V sought alternative private treatment.

24. When the care of a patient is shared between two doctors, usually a GP and a specialist, there should be a formalised written agreement/protocol setting out the position of each, to which both parties have willingly agreed. This is known as a shared care agreement.

25. The NHS England website section about responsibility for prescribing between primary and secondary care explains it is important patients are involved in decisions to share care and are clear about what arrangements are in place to ensure safe prescribing. In some cases, a GP may decline to participate in a shared care agreement if he or she considers it to be inappropriate. In such circumstances the consultant would take full responsibility for prescribing and any necessary monitoring.

26. The GMC guidance says if you prescribe based on the proposal or recommendation of another healthcare professional, you must be satisfied the prescription is needed, appropriate for the patient, within the limits of your competence and that you have enough information to safely proceed.

27. We asked our adviser about the GP's position in relation to anything that can be done for a patient seeking hormone replacement treatment in cases such as this where there is no established shared protocol for the local area for providing the medication. We asked whether there is there any alternative action a GP could or should take.

28. Our adviser says in accordance with the GMC guidance, it is up to the Practice to decide if the prescription is within the limits of their competence. This includes relevant arrangements for monitoring, follow-up and review. Our adviser said it is appropriate to decline to prescribe if the Practice did not feel safe or qualified to do so.

29. In this case, the Practice decided the prescription was outside of its competence as there was no shared care agreement in place and declined to prescribe. This is in line with GMC guidance.

30. We understand how important access to hormone therapy can be and how impactful this situation would have felt for Mx V. After carefully reviewing the circumstances, we consider the Practice acted appropriately and in line with the GMC guidance in its decision not to provide Mx V the hormone therapy treatment directly as it did not feel qualified enough to prescribe this.

31. We appreciate this has been a very difficult time for Mx V as they have been unable to get the treatment on the NHS they need. As we have seen no indications of failings, we will not investigate this part of their complaint any further.

Delays in complaint handling

32. Mx V complains about the length of time it took for NHS England to respond to the complaint. They say the level of communication was so poor they had to repeatedly chase the status and progress of their complaint and this has been the most upsetting part of the complaint. They say this led to them feeling ignored, dismissed and losing faith in the NHS.

33. The Local Authority Social Services and National Health Service Complaints (England) Regulations 2009 section 14 states that organisations have 6 months to respond to a complaint.

34. NHS England’s complaint policy says that complaints should be dealt with speedy and efficiently and states responses should be provided within 40 days.

35. NHS England took 29 months to respond to the complaint. Whilst we appreciate the complexity of the case and that NHSE were seeking responses from other organisations during this time, this far exceeds the 40 days which is referenced in its complaints policy and does not reflect speed or efficiency as also set out in its policy. This is also not in accordance with the Regulations or Our Principles which say complaints should be dealt with promptly.

36. We have therefore seen indications of failings in the way NHS England handled Mx V’s complaint, specifically the very long delay in responding.

37. Our NHS Complaint Standards say that Organisations should keep people informed of the progress of their complaint and provide regular updates throughout. The Regulations say that if a response cannot be provided within 6 months then the Organisation should notify the complainant and explain the reasons why.

38. During the period May 2023 to October 2025 we saw evidence Mx V was inconvenienced as they spent a great deal of time chasing for complaint responses. NHS England did not keep Mx V updated with reasons why it was taking longer than expected and providing a time frame for a response, and they had to continuously chase.

39. This lack of communication or updates is not in line with Our NHS Complaint Standards or the Regulations and is an indication of a failing.

40. We can see that the lengthy delay and the lack of updates led to Mx V feeling ignored, dismissed and losing faith in the NHS.

41. Our NHS Complaint Standards say that Organisations should look for ways to resolve complaints at the earliest opportunity. They also say that staff should identify ways to put things right for people, including apologising, and taking learning from a complaint.

42. We consider this matter falls into level two of our severity of injustice scale which says, ‘these are cases will generally be similar to, but more serious than cases involving level one injustice, but where we consider an apology on its own is not an adequate remedy. Typically, the injustice will arise from a relatively low impact failing, often resulting in a degree of distress, inconvenience or minor pain, but the duration of the injustice will tend to be longer than in cases with level one injustice. Examples include instances of poor complaint handling where there is a delay.

43. Mx V is seeking an apology, service improvements and financial remedy, and we think an appropriate amount is £300. This is based on our severity of injustice scale and awards made for similar complaints.

44. Therefore, we contacted NHS England and asked if it would be willing to resolve this complaint by providing an apology, service improvements and to pay Mx V £300. NHS England agreed to do this.

45. We consider NHS England has agreed to provide an appropriate resolution, in line with Our NHS Complaint Standards, and, as such, we will take no further action on this complaint.

46. Complaints give us a valuable insight into the organisations we investigate, and we recognise this has been a very distressing time for Mx V. We would like to thank them for sharing their experience with us.

1. We have carefully considered Mx V’s complaint about the GP Practice’s decision not to prescribe hormone therapy treatment. We have also carefully considered their concerns about NHS England’s complaint handling. We were sorry to hear of the impact this had on Mx V.

2. We have seen no indication the Practice was incorrect to decline prescribing this treatment. In relation to the complaint handling delays, we have decided NHS England has now done enough to resolve this aspect by agreeing to write an apology letter detailing its service improvements in complaint handling and agreeing to pay Mx V £300 in financial remedy. Therefore, we will not consider this complaint any further.