Immediate Action Required – Changes to Gender and Sex Identity Recording in GP Records Following Sullivan Review

The recently published independent Sullivan Review, led by Professor Alice Sullivan, has brought to light a critical safeguarding concern within the NHS. The review, which focused on data, statistics, and research relating to sex and gender, specifically highlighted the risks associated with the current process of re-assigning gender and sex identity in medical records for children and young people.

In response, the Secretary of State for Health and Social Care has announced immediate changes that directly affect general practice processes:

What’s Changing Right Now?

Effective immediately:

The process of assigning a new NHS number and changing the gender marker for patients under 18 has been stopped.

General practice teams may still update a patient’s name and title in the GP record.

•A reminder note can be added to the home screen of the record to reflect the patient’s preferred identity.

• Practices no longer need to apply for a new NHS number in these circumstances.

What Does This Mean for General Practice?

This national directive requires urgent updates to your current practice processes. Any team members involved in registration, coding, or record amendments should be briefed immediately, and interim processes clearly communicated to prevent inadvertent breaches of the new guidance.

At the same time, this change presents an important opportunity to:

Review and strengthen your internal governance procedures.

Ensure training is in place so staff understand the revised process and are aware of what they can and cannot do under the new rules.

Assess competency of those carrying out the updates.

Implement an audit process to track compliance and improve consistency.

Preparing for Future Guidance

The national direction signals that further guidance will be issued regarding how children and young people under 18 may record their gender identity in NHS records. This will require further updates to practice systems and potentially further training.

A Word on CQC and Inspection Readiness

It’s worth noting that national policy changes like this are often reflected in CQC inspections. Being able to demonstrate an up-to-date, safe, and well-governed process – backed by training records and audit – will stand your practice in good stead when the time comes.

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