Respond to the Scottish Government’s home abortion consultation

The deadline for responding to the Scottish Government’s consultation on home abortions is 5 January 2021.

All members of the public can respond. You do not have to live in Scotland.

You can respond to the consultation online here:

https://consult.gov.scot/population-health/early-medical-abortion-at-home/

There is also a separate consultation on home abortions in England which does not close until 26 February. This has similar questions, but not entirely the same, and we will update with guidelines for responding to that consultation in due course.

You can download our full response to the Scottish consultation.

Guidelines for responding the the questions

Please respond using your own words. Some suggested points to make in response to each question are provided below.

Question 1. What impact do you think that the current arrangements for early medical abortion at home (put in place due to COVID-19), have had on women accessing abortion services? Please answer with regards to the following criteria:

1. a) safety

Suggested answer: Negative impact

1. b) accessibility and convenience of services

Suggested answer: The impacts are mixed

1. c) waiting times

Suggested answer: The impacts are mixed

Comments

The most important points to make are about safety.

Do reference our Mystery Client Investigation as evidence.

Key points to make:

1. Eligibility cannot be clinically confirmed by telemedicine.
2. Safety for the woman cannot be clinically confirmed by telemedicine.
3. There have been some significant safety issues.
4. The identity of the woman has not been properly confirmed by telemedicine calls.
5. Providers cannot check that the woman is not being coerced.

Question 2. What impact do you think that the current arrangements for early medical abortion at home (put in place due to COVID-19), have had for those involved in delivering abortion services? (For example, this could include impacts on workforce flexibility and service efficiency.)

You do not need to answer this question.

Question 3. What risks do you consider are associated with the current arrangements for early medical abortion at home (put in place due to COVID-19)? How could these risks be mitigated?

We suggest making similar points about safety issues to those made in answer to question 1 above.

Make the point that these risks can all be mitigated or removed by reinstating the requirement for an in-person clinical assessment.

Question 4. Do you have any views on the potential impacts of continuing the current arrangements for early medical abortion at home (put in place due to COVID-19) on equalities groups (the protected characteristics of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation)?

Here you could mention the protected characteristic of pregnancy and make the point that pills by post abortions put women at greater risk of coercion or even receiving pills by deception.

You could also mention the protected characteristic of religion and say that those with conscientious objections should be able to opt out of any related services.

Question 5. Do you have any views on potential impacts of continuing the current arrangements for early medical abortion at home (put in place due to COVID-19) on socio-economic equality?

You do not need to answer this question.

Question 6. Do you have any views on potential impacts of continuing the current arrangements for early medical abortion at home (put in place due to COVID-19) on women living in rural or island communities?

We suggest that safety concerns mean that women living in rural or island communities should be required to travel to an abortion clinic for early medical abortion. Women who take these pills are warned that they should seek immediate medical assistance if anything goes wrong. Suggest that financial assistance can be provided if required, which could protect women who are particularly vulnerable to coercion.

Question 7. How should early medical abortion be provided in future, when COVID-19 is no longer a significant risk?

We suggest that as a minimum, the previous arrangements which require women to attend clinic before being given abortion pills should be reinstated.

You could also suggest that both pills be taken in a clinic because of the various safety concerns.