NHS England knows that its new guidance on single sex accommodation will harm patients.
Publicly, they say that the guidance offers “privacy, dignity and safety in hospital accommodation” – but internally, NHS England’s own Equality Impact Assessment shows that it may push trans patients out of the healthcare system altogether.
We believe that the public has the right to know the consequences of this policy change. So if NHS England won’t publish the full assessment, we will.
READ THE FULL EQUALITY IMPACT ASSESSMENT NOW
(Please note that the document’s revision date of October 2025 refers to when the template was last updated, not when the EIA was prepared.)
According to the document, changes to how trans people are accommodated within the NHS will lead to “a number of potential adverse impacts” including:
- experiencing fear and discrimination by being ‘outed’ as trans
- facing delays and being at a greater risk of receiving ‘corridor care’
- negative impacts on physical and mental health
- being forced into the distressing situation of being accommodated on wards based on sex assigned at birth
- and worsening relations between trans and cis people
Above all, NHS England acknowledges that these adverse impacts may lead to trans people avoiding accessing healthcare at all – something that our research shows was happening even before the new guidance.
NHS England’s impact assessment also highlights that cis women who are lesbian, bisexual and/or gender non-conforming may also be subjected to questioning on their sex and access to single sex accommodation.
But where the risks and impacts are clearly stated, steps taken to mitigate them are vague and undefined. Staff are encouraged to ‘consider the needs’ of each patient, and identify ‘alternative arrangements’ where needed – though what needs are to be considered, and what alternative arrangements are available, are left unsaid.
Likewise, the supposed benefits of the policy are nebulous too. The assessment repeatedly highlights that, for anyone who is not transgender, there are “potential positive impacts from the focus of the policy on privacy, dignity and safety”. Yet the document does not define what they are, or how trans people were ever a barrier to that privacy, dignity and safety in the first place.
The assessment also recognises that there may be circumstances where the “choice is between placement on a ward aligned with a trans person’s gender identity and not providing the required service”. The given solution – to prioritise the clinical needs of the patient – does not make clear how that would work in practice.
The assessment concludes that “trans people are likely to be disadvantaged by the approach to the provision of single sex hospital accommodation” and that “it is possible that the policy will not eliminate discrimination, harassment and victimisation, foster good relations or reduce health inequalities for trans people.”
If that doesn’t sound to you like the “privacy, dignity and safety” we were promised, email your MP today so they can see the harm that is being unleashed on trans people accessing hospital treatment in England. Make sure they cannot look away.
This action has been organised by Trans+ Solidarity Alliance, in conjunction with TransActual.