The patients might out themselves is a really interesting phrase tbh. I don't think they need to say anything about rape, because they are highlighting the sheer extent of a lesser problem and how the lesser problem is unacceptable. It doesn't have to be as serious as rape, for them to consider it a problem.
The 'outing themselves' seems to be a euphemism for 'likely to get their knob out inappropriately'. They have couched their wording but the implication here is actually explicit:
The issue of 'passing' is somewhat irrelevant because 'genitals are freely being offered for inspection, even when not requested'. Basically the wards acknowledge there is such a known problem with flashing, indecent exposure and sexual harassment that they can't even try and follow the Stonewall Law Bible because it's completely unworkable in that environment. And they haven't minced their words about this. They are saying it's male pattern behaviour. They aren't even trying to suggest that it's rare or unusual or uncommon for transwomen patients to do this. Indeed quite the opposite.
It's clearly not isolated cases for them to go that far and that 'anti-woke' given the culture across the NHS. You can deduce it's an active problem.
Which begs another question:
if some hospitals are identifying this as such a significant problem that they don't operate on the basis of gender (instead of sex) because flashing happens so frequently....
...then why isn't this being implemented universally by all similar units?
Any hospital which is out of step with sex on this, needs to really have some serious questions asked about it's management.