Tell the government not to extend DIY abortion policy

The following post relates to abortion policy in England. A similar Scottish consultation has already closed, and a separate consultation on Welsh policy is open until 23 February.

The Government has opened a new consultation on extending its dangerous DIY abortion policy. The measures were originally brought in to be temporary, however increasing pressure from the abortion industry has seen the policy extended over lockdown, even when abortion clinics opened up again. Now, the government wants to make this dangerous policy permanent.

Tragically, since its introduction in March 2020, many illegal and dangerous home abortions have taken place: no tests are given to women, putting their health increasingly at risk. You can read more about the dangers and risks of this policy in our ‘mystery client’ report.

It is important that the government hears as many of our responses as possible; the more people that respond to the consultation, the more the government will be pressured to stop this dangerous policy.

The consultation is easy to fill out as there are only ten questions, all with multiple choice answers. Below, we suggest how you can fill it in, together with the key points to make in ‘additional comments’. You can use the points below to fill it out in your own words.

The deadline for responding is Friday 26 February.

You can open the consultation here. You can use the points below as a guide to respond in your own words.

You can also find more practical tips on how and why to respond to the DIY abortion consultation, and how to make your voice heard, in our live abortion briefing:

Question 1: Do you consider that the temporary measure has had an impact on the provision of abortion services for women and girls accessing these services with particular regard to safety?

1. b) Yes, it has had a negative impact

Points to make:

• Home abortion is a painful and traumatic experience for women.
• Women may take the abortion pills past the 10-week limit – the abortion provider cannot correctly assess how far along the woman is in her pregnancy without the usual scans. Pills by post requires the woman to be accurate in her recall of the first day of her last period in order to assess gestational age, and puts that responsibility squarely on the pregnant woman.
• Vulnerable women can be forced into taking abortion pills.
• Providers cannot confirm the identity of the woman requesting abortion pills – in our mystery client investigation, in 26 cases out of 26, our team was able to obtain the abortion pills by post, even though they provided false information and were not pregnant.
• In a leaked email sent by a senior midwife at the NHS, a number of concerns were highlighted, including 13 related incidents including the delivery of a baby at 30 weeks gestation, 3 police investigations, one of which is a murder investigation as there is a concern that the baby was liveborn.
• The Department of Health and Social Care revealed it had been notified of 52 women who had been prescribed the pills for abortion at home in the first six months of the policy, where gestational age was beyond the 10-week limit.

Question 2: Do you consider that the temporary measure has had an impact on the provision of abortion services for women and girls accessing these services with particular regard to accessibility?

1. b) Yes, it has had a negative impact

Points to make:

• The telemedicine system is open to abuse and deception – the aim of medical care is not merely to adopt the cheapest or quickest approach. We must always consider the safety and wellbeing of those being served and compliance with the regulations.
• Where complications arise, the accessibility or convenience may well become a subject of regret.

Question 3: Do you consider that the temporary measure has had an impact on the provision of abortion services for women and girls accessing these services with particular regard to privacy and confidentiality of access?

1. b) Yes, it has had a negative impact

Points to make:

• The nature of telemedicine and speaking on the phone means that women may not be able to speak confidentially on the call without an abuser or coercive family member hearing.
• Women may go through traumatic abortion experience with only an abuser present at home.
• Although the abortion provider will usually ask the woman if she is alone and in a private place, there is no way to confirm this.

Question 4: Do you consider that the temporary measure has had an impact on the provision of abortion services for those providing services? This might include greater workforce flexibility, efficiency of service delivery, value for money, etc.

1. d) I don’t know (although if you work in the NHS, you may want to answer from your experience.)

Points to make:

• Most healthcare professionals will not be satisfied with these services as they know women cannot be properly or safely assessed by telephone to ensure that they are eligible for the abortion treatment at home.
• Costs may be reduced with telemedicine abortions, but this is not worth the lack of due care and compromising of safety, with possible complications.

Question 5: Have other NHS services been affected by the temporary measure?

1. a) I don’t know (although if you work in the NHS, you may want to answer from your experience.)

There are no additional comments to fill out on this question (unless you answer yes), however it is worth noting (and you can add these points at the end of the consultation) that due to complications in abortions, some 2-3% of women attend hospital to be treated for incomplete abortion; that’s around a couple of hundred women every month. The abortion provider is not the one managing these complications.

Question 6: What information do you consider should be given to women around the risks of accessing pills under the temporary measure if their pregnancy may potentially be over 10 weeks’ gestation?

Points to make:

• Women should be given full information about the risks of abortion carried out at any gestation and under any circumstances, but especially about the risks of taking the pills after 10 weeks.
• This question demonstrates the reality known to the government and the Department of Health and Social care that gestational age is a critical determinant of the safety and efficacy of medical abortion, and the fact that some women will not, or will not be able to, provide the correct information to enable the abortion provider to accurately assess gestational age.
• Women over ten weeks pregnant should be offered counselling so that they have the opportunity to think about keeping the baby and avoid an abortion which they could regret for the rest of their life.

Question 7: Outside of the pandemic, do you consider there are benefits or disadvantages in relation to safeguarding and women’s safety in requiring them to make at least one visit to a service to be assessed by a clinician?

1. a) Yes, benefits

Points to make:

• There are clear benefits to requiring at least one in-clinic assessment, including overcoming many of the safety and safeguarding gaps with exist in remote services. They include:
  • Verifying the identity of the woman;
  • Accurately assessing the gestational age of the pregnancy;
  • Assessing clinical eligibility.
• The risks to women carrying out a DIY abortion without visiting a clinic include:
  • Not adhering to the precise time intervals between two stages of the abortion;
  • Missing an ectopic pregnancy;
  • Emotional distress;
  • Domestic abuse.

Question 8: To what extent do you consider making permanent home use of both pills could have a differential impact on groups of people or communities?

Points to make:

• DIY abortions can increase abuse for pregnant women.
• Pregnant women who are abused are at greater risk from abortion.
• Religion or belief for healthcare workers who are asked indirectly to be involved with this service, eg. posting pills.

Question 9: To what extent do you consider that making permanent home use of both pills for EMA would increase or reduce the difference in access to abortion for women from more deprived backgrounds or between geographical areas with different levels of disadvantage?

Points to make:

• Poverty can drive women towards abortion, nor is abortion a solution for poverty.
• All women need to have an in-clinic assessment as part of their abortion care pathway.
• Access to abortion should be less important than the safety of the woman.

Question 10: Should the temporary measure enabling home use of both pills for EMA [select one of the below]…

1. b) End immediately

Have you any other comments you wish to make about whether to make home use of both pills for EMA a permanent measure?

Points to make:

• Allowing women to perform their own abortions at home should end immediately – this policy was never brought in with the intention of making it permanent, the government had promised it was purely a lockdown measure.
• Clinics are now open again, so women can go in to get the proper assessment.
• All women need to have an in-clinic assessment as part of their abortion care pathway.
• Taking abortion pills at home is promoted as being safe and simple, but it is fraught with risks and complications, as well as being traumatic for women.
• Complications after medical abortion are four times higher than after surgical abortion.
• The government should undertake a public information campaign to inform all women of the risks they run in having an abortion.