Tell the Welsh government to end DIY abortion immediately

The Welsh Government has opened a new consultation on whether to make DIY abortion a permanent measure.

The temporary measures were initially brought in in March 2020, however since healthcare is a matter for the devolved Welsh Assembly, it is consulting separately to England and Scotland.

Increasing pressure from the abortion industry has seen the policy extended across the UK over lockdown, even after abortion clinics were free to open again. Tragically, since its introduction, 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 eleven questions. Below, we suggest how you can fill it out, providing bullet points which you can make into answers. Please use this guide to fill out the consultation in your own words.

The deadline for responding is Tuesday 23 February. You can submit your response online, or download and email your response, or send it by post. All information can be found on the Welsh Government’s website.

Question 1: Do you consider that the temporary approval has had a positive impact on the provision of abortion services for women accessing these services with particular regard to safety, accessibility and convenience of services? Please provide your reasons.

• It has had a negative impact.
• 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 are unable to check that woman is not being coerced. There is not a safe private space for the woman to talk freely about whether she really wants to have the abortion or is doing so under pressure.
• 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.
• Where cost is a barrier to attending the clinic in person, we recommend that financial assistance should be provided by the NHS to enable an in-person consultation.

Question 2: Do you consider that the temporary measure has had a positive impact on the provision of abortion services for those involved with service delivery? This might include greater workforce flexibility, efficiency of service delivery, value for money etc. Please provide your reasons.

• 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.
• Caring professionals thrive on personal contact with their patients, including informal interactions which are not possible with telemedicine.
• 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 3: What risks do you consider are associated with the temporary measure? If you consider that there are risks, can these risks be mitigated?

• Providers cannot confirm the eligibility of a woman for early medical abortion at home. This has been clearly confirmed through our Mystery Client Investigation, which found that in all cases, women were able to obtain the pills by providing false information.
• Providers cannot confirm that it would be safe for the woman to have early medical abortion. Providers are unable to carry out a scan with telemedicine. A scan could reveal issues with the pregnancy which mean that the pills would be unsafe to take.
• Providers cannot confirm the identity of the woman requesting abortion pills.
• Complications in the pregnancy could be missed due to lack of scans and proper checks that would otherwise be done in clinic, eg. ectopic pregnancy.
• Providers are not able to confirm the gestational age of the pregnancy. Women could be given the pills even if the pregnancy is over 10 weeks’ gestation. There is too great an ease of access and too much dependency on the woman to be sure of gestational age.
• Providers are unable to check that the woman is not being coerced. There is not a safe, private space for the woman to talk freely about whether she really wants to have the abortion or is doing so under pressure from an abusive partner or parent.
• 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.

Question 4: In your experience, have other NHS Wales services been affected by the temporary approval? If so, which?

If you work in the NHS, you may want to answer from your own experience.

• Some 3% of women who take abortion pills up to 9 weeks’ gestation will need surgical treatment for an incomplete abortion, according to BPAS. This increases to 7% of women for those whose pregnancy is between 9-10 weeks’ gestation. The abortion provider is not the one managing these complications.

Question 5: Outside of the Covid-19 pandemic, do you consider there are benefits 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? Please outline those benefits.

• 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 6: To what extent do you consider making permanent home use of both pills could have a differential impact on groups of people or communities? For example, what is the impact on people with a disability or on people from different ethnic or religious backgrounds?

• DIY abortions can increase abuse for pregnant women. Similarly, pregnant women who are abused are at greater risk from abortion.
  • Pregnant women are in a high-risk category for domestic abuse, including pressure from their partners to obtain an abortion. The provision of DIY abortion increases the risk of coercion or even being deceived or pressured into taking abortion pills which have been obtained deceptively.
  • The Covid pandemic has seen increased levels of domestic abuse and the provision of telemedicine abortions has only increased the risks and pressures in this area.
• Religion or belief for healthcare workers who are asked indirectly to be involved with this service, eg. posting pills. Increased use of telemedicine abortion could result in more hospital and clinic staff being asked to indirectly be involved in the provision of abortion services. Many of these staff will have a conscientious objection to abortion due to religious beliefs and this should be taken into account in enabling such staff to opt out of providing any related services.

Question 7: 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 people from more economically disadvantaged areas or between geographical areas with different levels of disadvantage?

• 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.
• Financial assistance could be provided to women in poverty to enable women to travel to have an in-person clinical assessment prior to an early medical abortion.

Question 8: Should the temporary measure enabling home use of both pills for EMA: [multiple choice]

Use the box to comment.

• End immediately.
• As a minimum, the previous arrangements should be reinstated so that the various risks and safety concerns outlined above are mitigated and removed.

Question 9: We would like to know your views on the effects that the Termination of pregnancy arrangements in Wales would have on the Welsh language, specifically on opportunities for people to use Welsh and on treating the Welsh language no less favourably than English.

What effects do you think there would be? How could positive effects be increased, or negative effects be mitigated?

You do not need to answer this question, but you may want to if you have experience in this area.

Question 10: Please also explain how you believe the proposed arrangements could be formulated or changed so as to have positive effects or increased positive effects on opportunities for people to use the Welsh language and on treating the Welsh language no less favourably than the English language, and no adverse effects on opportunities for people to use the Welsh language and on treating the Welsh language no less favourably than the English language.

You do not need to answer this question, but you may want to if you have experience in this area.

Question 11: We have asked a number of specific questions. If you have any related issues which we have not specifically addressed, please use this space to report them:

• 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.
• The government should undertake a public information campaign to inform all women of the risks they run in having an abortion.