NHS Sussex Integrated Care Board (ICB) is the NHS body responsible for healthcare commissioning in Sussex, England. In 2025, it launched a controversial investigation into WellBN GP Practice for providing gender-affirming care to trans youth — after years of complaints from gender-critical campaigners.
The investigation has been covered by the Lemkin Institute for Genocide Prevention, which monitors global threats to vulnerable populations.
In 2025, NHS Sussex launched what it calls an "independent investigation" into WellBN GP Practice in Brighton for prescribing puberty blockers and hormones to under-18 trans patients — care that was legal and followed existing guidance for patients already on treatment.
The investigation was announced on June 5, 2025, following threats of a judicial review brought by:
According to TERF Watch Brighton, "no issues have been found in regards to this child by relevant regulators."
Additionally, CAN-SG (Clinical Advisory Network on Sex and Gender) had been filing complaints about WellBN and Dr Sam Hall for at least five years.
NHS Sussex published a factsheet on July 18, 2025 explaining the investigation. This document has since been removed from their website but is preserved in the Wayback Machine.
Download: WellBN Public Factsheet (July 2025) - PDF (permanent copy)
Key admissions in the factsheet:
On consent:
"Both NHS Sussex and NHS England have received legal advice that consent is not needed for the case note review to take place."
They cite GDPR Articles 6(1)(e), 9(g), 9(h) and claim "safeguarding the interests of children" as justification — while investigating care that was legal and followed guidance.
On prescription continuation:
"If the prescription started after 26 June 2024... the patient (parent) will receive a letter stating that prescribing cannot continue, the treatment can be safely stopped, and an offer of access to local CYP mental health services to support any distress of treatment withdrawal."
On progression:
"Can I / my child / young person move from puberty blockers to cross sex hormones while the case note review takes place? Not currently."
On anonymous reviewers:
"Will we know who the case note review team are? No. It is standard NHS practice not to share individual reviewer names."
On safeguarding:
"This review is not a safeguarding investigation, but if specific concern(s) is / are identified, they will be addressed appropriately."
This appears to threaten parents: cooperate or face safeguarding referrals.
Following a Freedom of Information request by TERF Watch Brighton, NHS Sussex released their Equality and Health Inequality Impact Assessment (EHIA) and Quality Impact Assessment (QIA) for the investigation.
These documents — completed by Kevin Holton, Head of Experience of Care and Equalities and Health Inequalities in NHS South East — contain damning admissions.
TERF Watch Brighton: NHS Sussex acknowledge "increased risk of suicidal ideation" (August 2025)
Download the documents:
Original NHS links (may be removed): EHIA | QIA
Suicide Risk — NHS Sussex's Own Assessment:
The EHIA states impacts "may include":
NHS Sussex acknowledges in their own assessment that their investigation may cause suicidal ideation — and proceeded anyway.
Discrimination Admitted:
"The EHIA acknowledges that this investigation discriminates on the basis of age and gender reassignment. However, they determine that this is a 'proportionate means of achieving a legitimate aim - protecting patient safety and addressing serious clinical concerns, as highlighted in the Cass Review.'"
They admit discrimination, then justify it via the discredited Cass Review.
No Actual Harm Found:
"As previously reported by TERF Watch, no concerns exist outside of those outlined in the Cass review, and no allegations of real harm have been upheld."
The investigation is based entirely on theoretical harms from Cass — not any actual harm to any patient.
QIA Conclusions:
The Quality Impact Assessment found:
By their own assessment, the investigation harms patient experience while providing no safety benefit.
DIY HRT Risk:
"The EHIA also considers the risk that individuals move to DIY and unregulated sources. Their only mitigation for this is the Single Point of Contact being instructed to advise patients against it."
They know forced detransition will push people to DIY — and their mitigation is just telling them not to.
Gender-Critical Talking Points in Official Document:
"The EHIA, while evaluating the impact on the protected characteristic of sex, mentions that 'some women's rights advocates' are concerned that trans healthcare impacts women's rights."
TERF Watch notes: "This point is irrelevant to the EHIA and we find its inclusion weird."
Gender-critical movement framing has been incorporated into official NHS impact assessments.
Adult Trans Experiences:
"The EHIA says that 'Adults have reported significant mental ill health linked to the inability to access gender-affirming care in childhood.' Despite this contradicting the claim in the Terms of Reference that one of the potential harms is 'loss of body autonomy in later life,' there are no recommendations to mitigate this."
They acknowledge adults suffer from not having childhood access — then do nothing about it.
The investigation's Terms of Reference reveal that NHS England and Sussex ICB decided the "risk of ongoing harm" was great enough to access patient information without individual consent.
TERF Watch Brighton reported:
A "vast amount of medical and personal information" has been requested for each child.
Meeting minutes from October 14, 2025 between WellBN and NHS Sussex ICB were leaked to North West Bylines, confirming that NHS England has "no provision" to continue prescribing to under-16s — directly contradicting government assurances.
North West Bylines: Is NHSE forcing young people to detransition? (archived)
Key exchanges from the minutes:
WellBN (Dr Marshall-Andrews): Patients have been waiting to see if there would be an offer of ongoing care. Is it being said that that will not happen?
NHS Sussex ICB (Dr Andrew Hodson): "The offer of care will consist of referrals to mental health and gender services. There is an assumption in the terms of reference that prescribing would need to be safely discontinued... I feel the need to steer away from the assumption that there would be a possibility of continued prescribing."
WellBN: For the under 16s, these prescriptions have been initiated by other gender services, such as GIDs or Anne Health. The understanding has always been that GPs could continue the prescribing from these services.
Dr Hodson: "NHSE's stance is that there is no provision for this... NHS prescribing of puberty blockers by WellBN will be stopped."
He acknowledged "there is an issue with patients being 'driven into' private services."
WellBN staff: "Some of these patients have letters from NHSE telling them that prescribing could continue by an NHS GP. These families have done exactly as told by NHSE. How can there now be no foundation for them to continue?"
Dr Hodson: "This is a prescribing issue where the service is not commissioned to prescribe in the way it has. The outcomes for the under 16s, on the basis of the investigation, will be that there is no GMS service for this care. Challenging this could be done from the patient perspective."
He stated there will be "a likely outcome of deprescribing."
"Olive's" Letter to NHS Sussex ICB:
A 16-year-old patient ("Olive") wrote directly to the ICB:
"Before the investigation... I was the happiest I have ever been. I was doing well in school, I was healthy and happy."
"Whereas now, during the investigation, I cannot even eat because of how scared I am for my future, I cannot focus in school anymore because the constant thoughts of me even being alive in the future haunt me everyday."
"If my life saving medication is taken off of me I have no doubt in my mind that I will end up taking my own life."
"You can sit there as snug as you want, reading off a script, practically giving out deathwishes to children."
"You expect me to walk down the aisle at my wedding with a beard and a deep voice all because YOU don't agree with the choices that I made in MY life."
"You ALL have blood on your hands and there will be far more to come based on the decisions YOU make."
Olive's mother ("Laura"): "If and when Olive takes her life, I hope the NHS and the ICB are willing to stand beside me in a coroners inquest and a public inquest, because believe me, I am not going anywhere!"
Anonymous Review Team:
The investigation team's names are secret. NHS Sussex claims this is "standard NHS practice" — but it prevents scrutiny of potential conflicts of interest or anti-trans bias.
No Family Contact:
Per parent testimony, the anonymous team reviews patient files and decides treatment plans "without ever having a conversation" with the families or young people affected.
Northwest Bylines: NHS threatens GP practice over trans care (November 2025)
Harm Definition Based on Cass Review:
Per TERF Watch Brighton, the investigation's analysis of harms relies "entirely on the widely medically discredited Cass Review." The Terms of Reference do not refer to any cases where harm has actually been reported.
Anti-Neurodivergent Framing:
The investigation "frequently makes reference to the possibility of children treated by WellBN being neurodiverse, referencing anti-trans stereotypes and ableist implications that neurodiverse people have different capacities for body autonomy."
Threats to Close Practice:
NHS Sussex twice threatened to withdraw WellBN's GMS contract (April and September 2025), which would close a practice serving 26,000 patients.
Data Breaches:
Parents reported that after they "said no to [NHS Sussex] accessing our patient files... they still breached data."
Forced Detransition:
Despite government guidance stating patients already on treatment could continue, NHS Sussex ordered that under-16s can no longer receive puberty blockers "regardless of the fact that these are children who were prescribed before the ban."
Per the factsheet, prescriptions started after June 26, 2024 will be stopped entirely.
Blocking Private Care:
Parents were told NHS Sussex is "working on laws to stop us accessing private health care also."
The factsheet ominously states: "NHS England strongly discourage going to unregulated providers for any care."
In November 2025, North West Bylines published extensive testimony from affected parents titled "Parents say: They are killing our children" (since removed from the site).
Archived: Parents say they are killing our children (November 2025) (MHTML format)
Note: This article was published November 19, 2025 and removed from the site approximately one month later. The reasons for deletion are unknown.
Parent testimonies:
"The care our daughter has received from WellBN has been outstanding – inclusive, affirming, evidence-informed and life-changing. Her wellbeing has significantly improved since starting gender-affirming care."
"For our daughter, care from WellBN has been quite literally life-saving. Her mental health has stabilised, her distress has dramatically reduced, and she is finally thriving after years of uncertainty and fear. To hear that this small but vital service is now under review feels like the lifeboat we are clinging to is being deliberately rocked; or worse, dismantled."
"GIDS have not prescribed to any child since the ban began. In fact we all know families who have had to detransition their children because they refuse to continue prescribing even though they are on them legally. Families have had police turn up to their appointments because they refuse to stop their child's blockers, that they received legally."
"Utterly disgusted, my husband wants to kill himself because of what the investigation is doing."
"My child's voice should be paramount in a decision about their own body and care."
Parents described finding WellBN as "life-saving" and "six months of support bliss" before the investigation began.
Dr Sam Hall (formerly at WellBN) stated: "No trans youth have been harmed in the service he set up in 2020. On the contrary, we have pages of evidence of quite the opposite. NHS Sussex are themselves causing a huge amount of harm."
Police involvement: Multiple families reported police being sent to appointments because they refused to stop their children's legally-prescribed blockers.
Social services referrals: Many parents spoke of being referred to social services "as many as six times" by the ICB.
Regional centres described as "death sentence": Parents fear referral to NHS GIDS regional centres means forced detransition. One parent said it "would be a death sentence" to send their child to such a service, citing stories of "patients as young as 11 being continually asked about their genitals and sex life."
Anne Health, which has families from WellBN, stated:
"We are sickened and dismayed by the investigation into WellBN GP Practice by NHS Sussex. This action goes entirely against the principles of the NHS constitution, which promises care based on clinical need, not political pressure."
"Children who were thriving are now facing forced puberty in the wrong gender. Parents are watching their children deteriorate before their eyes."
"This is not healthcare. This is cruelty dressed up as 'safeguarding.'"
Anne Health: Response to NHS Sussex Investigation into WellBN (2025)
Parents have reported:
Meanwhile, CAN-SG describes the same children as being "harmed by these hormones."
The investigation's stated outcomes include referral to:
TERF Watch Brighton noted: "As part of the investigation, trans children receiving care will be transferred to other NHS services, in all cases having care retracted."
Dr Sam Hall was a GP partner at WellBN until June 30, 2025. He stated in July 2025: "I've been doing [it] for the last five years with the full knowledge of everybody in the system… What's changed? Nothing. I'm not doing anything different."
WellBN stated his resignation was submitted in September 2024 with a nine-month notice period, though TERF Watch characterized his departure as being "ousted" in relation to the investigation.
NHS Sussex's official page frames the investigation as responding to "concerns raised about some prescribing... that may fall outside of the statutory framework."
However, continuing prescriptions for patients already on treatment explicitly falls within government guidance, which stated: "NHS patients who are already receiving these medicines for gender incongruence and/or gender dysphoria can continue to access them."
NHS Sussex: WellBN Investigation Page
Judicial review threat:
Complaint originators:
Government alignment:
Documenting the investigation:
The ICB has stated it intends to implement a "robust tracking approach" for affected families:
An anonymous artist documented the investigation's impacts through a series of illustrations, with permission to share on Growing Up Transgender:
The illustrations depict:
The article notes: "Many [families] are trying to find ways to flee the country."
On March 9, 2026, NHS England published 10 "evidence reviews" claiming hormone therapy evidence is "low quality." Analysis by Erin Reed revealed systematic manipulation:
"Salami slicing": Split into 10 artificially narrow reviews by exact hormone combination and binary/non-binary identity — guaranteeing each piece too small for conclusions.
97% exclusion rate: 547 full-text screenings → only 17 studies included
Circular exclusion: NHS's own data shows 98% of patients followed the Dutch Protocol pathway. Every review was designed to exclude that pathway.
Gordon Guyatt — the McMaster researcher who invented "evidence-based medicine" and developed GRADE — called using systematic reviews to justify banning care "egregious and unconscionable."
A low GRADE rating reflects study type, not whether treatment works. Over 90% of all medicine lacks "high-quality" GRADE evidence.
The equalities impact assessment reveals NHS England is "separately reviewing the evidence for the use of MAF in adults with gender dysphoria, with the aim of a consultation on the evidence later in 2026."
Erin in the Morning: New NHS England Review Excluded 97% Of All Trans Studies (March 2026)
The Sussex ICB investigation demonstrates how NHS bureaucracy is being weaponized to force detransition of trans youth who were legally receiving treatment. The Lemkin Institute's coverage — an organization focused on genocide prevention — signals the severity of what's happening.
Key features:
This is not a patient safety review. It is coordinated forced detransition.