The former CEO of trans youth charity Mermaids is launching a private clinic that will “exploit a legal loophole” to bypass the ban on puberty blockers, i can reveal.
Susie Green, who left the controversial charity in 2022, will open Anne Health this weekend to provide a range of medical, pharmaceutical, and psychological support services – including puberty blockers, hormone treatments, and counselling – to transgender people of all ages.
In an exclusive interview with i, Ms Green said her clinic will be “as safe an avenue as possible” for trans youth but the announcement is expected to provoke a backlash.
- Legal loophole that allows access to puberty blockers
- The work and life of Mermaids’ Susie Green
- The debate over giving puberty blockers to children
- Personal story behind the Anne Health clinic
The launch of Ms Green’s new service comes as Health Secretary Wes Streeting announced the Government would extend the ban on puberty blockers first put in place two months ago by the Conservative government.
Mr Streeting said he would make the ban – which is only effective only until September – permanent. Writing on X (Twitter) this week about the use of blockers in gender treatment he said: “we don’t yet know the risks of stopping pubertal hormones at this critical life stage”.
It is four months since NHS England stopped doctors in gender identity clinics providing the medication to trans young people, days ahead of the publication of the Cass report, which raised concerns about the safety and efficacy of puberty blockers for adolescents, but which did not recommend a ban.
In May, previous Health Secretary Victoria Atkins invoked emergency powers to prevent private or off-shore clinics from prescribing puberty blockers to children “to address risks to patient safety”.
But the loopholes that Ms Green’s clinic will use to provide medication to young people raise questions about the effectiveness, scope, and robustness of the government’s ban. i understands that DHSC officials are willing to explore the possibility of criminal sanctions against anyone involved in the supply of puberty blockers.
A legal challenge to the ban on private providers of puberty blockers was lodged in the high court last week, prompting a further escalation in the disagreements surrounding the medication.
Ms Green said there would be no minimum age for patients at her clinic. “We will support whoever comes to us,” she told i, explaining that for those too young for puberty blockers “there’s a pre-medical pathway” which would involve psychological support.
However, Anne Health will not see anyone under 18 without parental consent, said Ms Green. “When someone signs up, they’re entering into a contract with us and you can’t do that legally with someone under 18.”
A parent will need to be present with the patient during consultations, she said, and the clinic will use photo ID such as passports to verify the parent-child relationship.
The clinic will defer to treatment protocols established by WPATH, the World Professional Association for Transgender Health, she said.
WPATH is not without controversy. It is a membership-funded advisory body that provides guidance on transgender health to a wide range of organisations, but has come under fire recently for using low quality sources. Ms Green co-authored the most recent version of its guidelines.
But it is the routes by which Anne Health seeks to “exploit the legal loophole” on puberty blockers that is likely to divide reactions.
The legal loophole that allows access to puberty blockers
The main route is enabled by a simple, glaring omission in the legislation – the government could have banned the importation of puberty blockers but did not.
Ms Green told i she sought legal advice from David Lock KC, one of the lawyers challenging the ban in the high court, and prior to that had contacted Jolyon Maugham, a KC, and a campaigner for trans rights. He is the director of the Good Law Project, which is supporting the high court case.
Last month, Mr Maugham wrote on X about the parameters of the ban and its “loopholes”: that the former health secretary’s new regulations “prohibited the sale or supply [of puberty blockers] – but not the importation”. And that the ban, despite its stated aims, doesn’t stop EU doctors providing prescriptions for puberty blockers nor EU pharmacies fulfilling such a prescription. Instead, he explained, it stops (in most cases) UK pharmacies dispensing the medication.
“So you can get your EU prescription fulfilled at an EU pharmacy and lawfully bring those puberty blockers back into the UK,” he wrote, as long as it is for your own use not someone else’s, otherwise it constitutes “supply” which is covered by the ban.
Despite the ban claiming to stop foreign doctors prescribing puberty blockers to British children, in practice it cannot, according to Mr Maugham, who told i, as an example: “The French couldn’t tell British doctors what British doctors are allowed to prescribe and nor can we tell French doctors what French doctors are allowed to prescribe.”
Ms Green forwarded to i the legal advice she obtained from David Lock KC. It confirmed the opinion of Mr Maugham, that the ban doesn’t cover either possession of puberty blockers, the use by a patient of this medication, nor its importation. And the attempt to criminalise those prescribing puberty blockers outside the UK to British young people cannot be effective.
“In our opinion the Regulations do not criminalise any conduct by an individual if that conduct takes place wholly outside of the UK,” wrote Mr Lock.
“It follows that a person (even if usually resident in the UK) will not commit a criminal offence under the Regulations if he or she is party to the sale or supply of PBs where the relevant act takes place wholly outside of the UK.”
Therefore, “there would be no breach of the Regulations if a young person (alone or in the company of an adult) were to travel to an EU country with a view to securing access to PBs and then for the young person to bring the drugs back into the UK for his or her own use.”
Ms Green, using this advice, established a route by which she believes her clinic can help provide puberty blockers to under-18s. First, Anne Health is hiring clinicians – nurses, doctors, and endocrinologists – who are not based in the UK (even though the company is) which means their specialist doctors in the European Economic Area are free to write prescriptions and “are regulated by their own medical bodies outside of the UK”.
Then, once prescribed, because the ban relates to England, Wales and Scotland but not Northern Ireland, the prescriptions will be sent to alternative addresses in Northern Ireland, from where patients from mainland Britain can collect them. “We’ve got a network of Northern Ireland families who are willing to take receipt of medication sent to them,” said Ms Green. “The families just need to go over there and the kids need to get the medication and if they bring it back it exploits this legal loophole.”
The high court challenge to the ban, which was brought by the advocacy group TransActual and a private individual, is based on procedural grounds: alleging that, for example, the former health secretary misused the emergency powers by failing to undertake sufficient clinical or scientific advice; and by failing to consult with relevant patient groups affected by the ban.
i understands that DHSC officials are willing to explore criminal sanctions against anyone involved in the supply of puberty blockers, although this would be difficult or impossible in the case of foreign doctors.
The high court’s response to the challenge is expected in the next week.
The work and life of Mermaids’ Susie Green
Both Ms Green and the support and campaign organisation Mermaids have been dogged by controversy for several years now. She stepped down from her role as CEO of Mermaids in November 2022, three days before the Charity Commission opened a statutory inquiry – still ongoing – over concerns about governance and management at the organisation.
Both Mermaids, which provides training to the NHS, schools and police, and Ms Green have come under sustained criticism including accusations of pathologising children and encouraging them to transition or embrace a trans identity simply for not adhering to gender norms – which Mermaids and Ms Green reject.
An investigation by The Telegraph in September 2022 alleged that Mermaids had offered to send chest binders to an undercover journalist posing as a 14-year-old, without the parent’s knowledge. The article initiated scrutiny of Mermaids by the Charity Commission.
The same year, it was claimed that harassment and abuse of staff at the charity, which was founded by volunteers in 1995, became so severe that it led to the temporary closure of its helpline. Prominent campaigners for trans people, including the author Paris Lees, have described the charity’s work as “life-saving”.
Ms Green’s family life has frequently been in the spotlight as she shared the story of her own trans child and their treatment. She was falsely accused by Catholic commentator Caroline Farrow of having “castrated” and “mutilated” her child, after taking her then 16-year-old to Thailand for gender surgery. Jackie, Ms Green’s daughter, has said she would not still be alive without her mother’s support.
After leaving Mermaids, Ms Green went on to work for GenderGP, an online trans healthcare provider set up by Dr Helen Webberley, which offered access to puberty blockers alongside other support and therapies. Ms Green left after a few months when she became “unhappy” with how things were being done, she said.
The debate over giving puberty blockers to children
Puberty blockers have become a focus of debate surrounding transgender rights, and in particular the best approach for gender-dysphoric or gender-incongruent children.
The rationale for their use was that blockers represent a method by which to pause the development of children questioning or sure about their gender identity being different to their birth sex.
It is an approach used by numerous countries around the world. They were first prescribed to patients in 1988 by endocrinologist Dr Louis Gooren, at a clinic in Amsterdam, and have been offered more broadly in the Netherlands since 2000.
When Health Secretary Wes Streeting announced the ban on puberty blockers he wrote on X: “Children’s healthcare must always be led by evidence. Medicine given to children must always be proven safe and effective first.”
The ban follows the publication in April of the Cass Review, an independent report into NHS healthcare for trans youth.
In July 2022, Dr Cass advised that a trial should be considered for “rapid establishment” to determine treatment protocols. Two years on, the trial has yet to be launched.
This looks set to change, however, with Mr Streeting announcing last week that, “the NHS [is] establishing a clinical trial with NIHR [National Institute for Health and Care Research] to ensure the effects of puberty blockers can be safely monitored and provide the evidence we need.”
Currently, the treatment (whose medical name is gonadotropin-releasing hormone agonists or GnRHAs) is provided by the NHS for a variety of reasons, including cancer treatment and to children who experience premature puberty – but the ban only relates to its use in gender care, prompting some to argue that the ban is discriminatory.
Mr Streeting said that while little is known about the effects of stopping the natural surge of hormones experienced during normal puberty, use of the drugs in young people experiencing precocious puberty “has been extensively tested (a very different indication from use in gender dysphoria) and has met strict safety requirements.”
Concerns surrounding the use of puberty blockers include a lack of data on how their use affects cognitive development and fertility, as well as risk of cancer and metabolic disease. Mr Streeting singled out “psychological and brain development” as key areas that could be affected.
The personal story behind the Anne Health clinic
The idea behind Anne Health arose last year when England and Wales’s only NHS service for trans youth – the GIDS clinic at the Tavistock and Portman NHS Trust – was being wound down for closure, with thousands on its waiting list and patients waiting up to four years for a first appointment.
“There are so many people who are struggling, who have got no other option, young people in particular with the horrendous waiting lists,” said Ms Green. GIDS has now been replaced by two hubs, one in London and one in the north of England. They do not provide puberty blockers or hormone treatments for under-16s. As some turned to online private clinics, the health secretary imposed a ban on puberty blockers.
Ms Green decided to exploit the legal loophole in the ban.
“We want to provide as safe an avenue as possible for people to access medical healthcare,” said Ms Green.
The co-founder and co-director of Anne Health Ltd is Lizzie Jordan, a longstanding HIV activist and sexual health advocate, and the CEO of Think2Speak, an LGBT+ support service for young people and their families. Both Ms Green and Ms Jordan have loved ones who are trans. Neither director is medically trained nor qualified in psychotherapy, endocrinology or clinical psychology.
“We’re seeking to provide the sort of healthcare that we wish our loved ones had had,” said Ms Green. Nearly 20 years ago, she travelled to the US to find puberty blockers for her 13-year-old. From the age of four, Ms Green’s child said she thought she was a girl, and was then referred to the GIDS service at seven, but as puberty was approaching suffered increasing psychological distress and attempted suicide. At the time, the NHS didn’t provide puberty blockers to under-16s. “So I had to go abroad, it was hugely expensive, I had to remortgage my house,” said Ms Green.
The services her new clinic will provide include counselling and psychological support, diagnosis, prescriptions, and endocrinology care, such as blood tests and monitoring. Importantly, she added, it will also offer consultations, on the phone, or by video call, enabling patients to have medical advice and support from clinicians. “People will actually talk to a doctor and have a doctor in charge of their care,” she said.
The only other online private clinic for trans patients that prescribes to under-16s is GenderGP, which now uses AI algorithms rather than health advisers – blood tests are evaluated by an algorithm, prompting concern. Its founder, Helen Webberley, told The Times recently, “We fed the algorithms the respected clinical guidelines” therefore removing the “human interpretation of protocol”.
Ms Green, whose professional background before Mermaids was at the Citizens Advice Bureau, worked at Gender GP last year but became disillusioned by its approach and decided to leave.
In May a court ruled that GenderGP, which is Singapore owned and unregulated, had prescribed dangerous levels of hormones including puberty blockers to a 15-year-old trans child who is also autistic. The child had not spoken to a doctor. The events occurred in 2022, before Green worked there. On Friday, Webberley’s license to practice as a doctor was revoked by the General Medical Council, after she failed in the legal duty common to all doctors to revalidate her license every five years.
The six counsellors and psychotherapists attached to Anne Health are members of the British Association for Counselling and Psychotherapy, said Green, and led by Marianne Oakes, a registered (but not accredited) member of the BACP.
Asked what she would say to anyone questioning what qualifies her to open this clinic, without her own medical or psychological training, Ms Green said, “I’ve got over 20 years of [experience] supporting trans young people and their families. I have experience of supporting thousands of families navigate their way through. I also know what it feels like.”
Ms Green admits to having had doubts about establishing the clinic.
“To be honest, Lizzie [Jordan her co-founder] and I have said to each other, ‘Are we mad doing this? Because they’re going to come after us.’ But at the same time, nobody else is doing it and all these kids have been hung out to dry. They’re not getting any support.”
Following the closure of the GIDs clinic at the Tavistock earlier this year, gender dysphoric young people are now referred to a regional specialist clinic where, according to NHS England, they will be assessed by a multidisciplinary team of psychologists, therapists, a psychiatrist and a social worker before being offered suitable treatment, which no longer includes puberty blockers.
Ms Green’s daughter, Jackie, has spoken publicly about her own experiences, but Ms Green describes them here.
“She’s said that if she didn’t have access to a medical pathway she wouldn’t even be here, that she would never have survived going through a male puberty,” said Ms Green.
“She was terrified of becoming more masculine. As soon as puberty started and she started seeing things happening to her body she started self-harming. I made steps to stop her from having to live through that, because I didn’t think I could keep her alive.”
Online critics, meanwhile, have accused Ms Green of making her child trans to avoid having a gay son. She scoffs at this. “I’ve got a gay son,” she said. “I’ve got a trans daughter, a gay son, and two hetero sons.”
The name of the new clinic arose from an elderly aunt of her business partner, Ms Jordan. When a loved one of Ms Jordan came out as trans, her aunt was particularly supportive. It prompted Ms Jordan to believe, said Ms Green, that “everyone needs an Anne in their life”.
A spokesperson for the Department of Health and Social Care told i: “Decisions on our children’s healthcare must follow the evidence at all times. Dr Cass’s review found there is insufficient evidence to show puberty blockers are safe for under 18s. That’s why the NHS has already stopped their routine prescription for children with gender dysphoria, and why we have extended the ban to private providers.
“We are committed to ensuring children questioning their gender receive the best possible multidisciplinary care, and don’t have to wait years for it. That is why we are reforming gender identity services.”
