AC-2024-LON-001142 - [2025] EWHC 2015 (Admin)

Amy Robson was the CQC’s registration inspector who carried out the registration assessment for IP1. They have a PhD and a level 5 in health and social care management, and previously worked as a manager for a health and social care service.

Amy Robson has explained that, at around the same time as IP1’s application for registration, it was identified that there was a need for the CQC to have a standard operating procedure for the registration of private providers of gender identity services, including specialist endocrinology interventions. Amy Robson was involved in this process, bringing together others with appropriate expertise to assist; regard was had to the Cass Review interim report, and it was recognised that those assessing providers of gender identity services would need to be familiar with this and other relevant guidance; more specifically, the limited evidence available as to the outcomes of the hormone treatment was expressly acknowledged, meaning there would be a need to ensure that providers had robust consent processes in place.

In assessing IP1, Amy Robson led a team that also comprised a regional medicines manager, a national professional adviser for primary medical services and integrated care who had oversight for on-line provision, and a senior specialist in mental health who had been involved in the inspection of Tavistock GIDS and had experience of mental health services. The assessment framework used identified five key questions relating to the provider and the services to be provided: are they safe; are they effective; are they caring; are they responsive to people’s needs; are they well led? In completing the assessment, specific regard was had to a number of guidance documents, including the Cass Review interim report, relevant NHS guidance, and the inspection history of Tavistock GIDS. The paperwork obtained from IP1 was fully assessed, and additional information and clarification obtained; the process included meetings with Dr Kelly and Mr Carruthers, and a separate fit person interview with Mr Carruthers. A (59-page) research and planning evidence record was produced, dated 11 December 2023, which included Amy Robson’s analysis of evidence collected during the assessment and their recommendation to grant registration.

In her evidence in these proceedings, Amy Robson has confirmed their awareness at the time of undertaking this assessment of the sensitivity around the hormone treatment, and that they had specifically considered the content of Cass Review interim report and the NHS position at that time. She has explained that the assessment team considered the evidence provided by IP1 against the criteria for endocrine treatment in the NHS commissioning policy then in place, concluding that it was broadly aligned; specifically, the evidence demonstrated there would be: (a) assessment by a MDT over a period of time, which would include a medical practitioner with specialist expertise in gender incongruence in children and adolescents; (b) continued psychological support through engagement with the MDT; (c) no hormone treatment before age 16; (d) discussion about the impact on fertility; (e) parental involvement in decision-making; (f) robust processes for seeking consent; and (g) involvement of a consultant endocrinologist in the service provision.

A management review meeting was held on 14 December 2023 to consider the recommendation to grant registration, at which it was determined that a condition should be imposed that would prevent the provision of TDDI to those under 16. Further oversight was provided by the CQC’s director of national operations, chief inspector of adult social care and integrated care, and the senior government engagement officer, before registration was confirmed on 9 January 2024.

Subsequent to the registration decision relating to IP1, in or around April 2024 the regulatory leadership within CQC (which is distinct from its operational activities) established a CQC Cass oversight group, headed up by Janet Kirton de Ortega, a deputy director for primary and community care. The purpose of this group was to provide oversight of CQC activities relating to the regulation of gender identity services, and it then took forward the standard operating procedure for the registration of such services.