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The “Gender Affirmation Care” Rebuttal for health professionals

This resource is provided for Australian psychologists or health providers brought before AHPRA for ethical non-compliance to the 'gender affirming care' model.


Late last year, a psychologist friend of mine attended an online seminar presented by a young psychologist two years out of University, who instructed attendees on how to treat those who are trans gender diverse based on her Master’s thesis and lived experience as a Non-Binary Gender Fluid/Gender Queer.  The presenter took issue with the questions and concerns my friend raised at the end of the seminar via the online feedback form presented, as contrary to APS’s status quo. The presenter’s organisation follows the current guidelines of the Australian Psychological Society (APS), however since January 2022, APS has engaged a task force to review the evidence regarding the model and therapeutic approaches associated with Gender Affirming Care (GAC), as yet incomplete.

Across the world in Finland, France, UK, Norway and Sweden where systematic reviews have been conducted, peak health bodies have changed their policies substantially to a more cautious approach and no longer follow the gender affirmative care model. Similarly in Australia, the National Association of Practicing Psychiatrists (NAAP) and the Royal Australian and New Zealand College of Psychiatrists (RANZCP) have rolled back ‘gender affirmative care’ as a policy. NAPP has released a sets of guidelines recommending psychotherapy as the first line of treatment for gender dysphoria in youth, as result of systematic review of the evidence. RANZCP in the PS103 say that they do not privilege any particular treatment guideline or approach and individual clinicians need to do their own research and make a decision based on the patient's needs.

My friend raised concerns of the medical harms of GAC model, the trauma of families being told to affirm their child’s intent to remove healthy body parts, the ideological basis of GAC, the lack of, or low quality evidence supporting it, and that GAC is a form of conversion therapy by ‘gender identity, for the LGB community. Underpinning her concern was the ethic ‘do no harm.’

In response, the presenter’s clinic reported her to AHPRA. That is not surprising Dr Damien Riggs as the key writer on gender affirmation for APS’s journal Insync advises that non-affirming psychologists be reported to the regulatory board. He also recommends that parents who do not affirm their children as the opposite sex, be reported to child protection services. Dr Riggs however is not a registered psychologist. It is not consistent with an evidence based science, to suppress or sanction those who query harmful policy and practices in healthcare. Failing to stay up to date with significant research is not only negligent but also goes against the best interests of patients.

It is very important to note that guidelines change with evidence. Guidelines are not protocols and there is no single standard of care as there is no evidence for Gender Affirming Care in a clinical setting.

There is no scientific consensus on the model of care for trans gender diverse, which means that my friend could not have breached guidelines which are in active dispute, and which look to be dangerously out of date. This scenario is playing out with other psychologists in Australia, I queried one other senior psychologist, and he reported that two others have been brought before AHPRA for being non-compliant in the last 4 weeks.

Hence Active Watchful Waiting has prepared these resources for health care providers in that situation to cut and paste from to address the specific type of complaints that may be brought against you.

If you are brought before AHPRA here are a few tips:
Consider your audience. The first people addressing your complaint are the administration staff, they are only qualified to see whether the complaint is complete bogus. They have no legal or medical qualification.
The second group are their lawyers and the last group are the medical professionals.

If you have public indemnity insurance, use it. It will save money. If you are in a state that legislates ‘gender affirming care’ i.e., conversion therapy bans via gender identity, engage a lawyer. This is a fraught area, psychologists are being brought to court in Australia for damages done to their clients through following the gender affirmative care model.

APHRA are in the process of forming their own code of ethics, but it is a number of months away. So you will be primarily addressing APS's code of ethics. 

SECTION 1: There is no consensus on the Gender Affirmation Model of Care

SECTION 2:  Gender Identity’ and ‘Gender Affirming Care’ - Myths, Untruths, Unproven and False Assumptions

SECTION 3:  Medical Damages of Gender Affirming Care

SECTION 4: Recent articles via investigative journalism of the Damages of Puberty Blockers, Cross-Sex Hormones and Genital Surgeries as part of Gender affirming Care.


SECTION 5: Overseas peak body health organisations after systematic review move away from GAC.

SECTION 6: Controversies around the GAC guidelines and practices of WPATH & Endocrine Society, AusPATH, APS, & ACON

SECTION 6: Controversies around the GAC guidelines and practices of  ACON (part c)


SECTION 6: Controversies around the GAC guidelines and practices of  APS (part d)

SECTION 6: Controversies around the GAC suppression of alternative therapies (part e)

SECTION 6: Controversies around the GAC guidelines and practices of  AUSPATH (part f)

SECTION 7: Paper for the Family Law Profession Gender Identity in children and adolescents (May 2023) by Barrister Belle Lane

Feel free to reach out to be put in touch with other psychologists who have been through this process. put 'gender affirming care help' in the subject line.

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