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How to respond to Government consultation on DIY abortions

On Friday 26th November the Government opened a public consultation asking whether the new Early Medical Abortion (EMA) measures “should be made permanent” after COVID laws are scrapped. CBR UK are advising as many people as possible to fill it in and have provided support material and information below.

The consultation consists of 10 questions and takes around 30-45 minutes to complete.  The deadline for responses is the 26th February 2021.

About the measures

The measures, introduced on 30th March under the guise of COVID, permit the home as an “approved” place for women to take both abortion pills (mifepristone and misoprostol), after a telephone consultation with an abortion clinic lasting between 30 minutes and 1 hour.

Far from helping people “stay at home, protect the NHS and save lives” these pills have turned homes into backstreet abortion clinics, had major implications on women’s health and claimed the lives of an estimated 46,000 unborn babies between April and September 2020, (the majority of which would have been placed into domestic waste or flushed down the toilet). 

It is imperative that we speak up in order to prevent the killing of innocent human beings , the harming of misinformed women and the turning of homes into abortion clinics. 

So how important is this consultation?

This consultation is likely to become the most important battle ground in deciding the fate of these measures. We can expect the abortion industry (BPAS, NUPAS and Marie Stopes) to come out in full force proclaiming how safe and effective these measures are, with supportive contributions from the Royal Colleges  (RCOG and RCOM) and abortion advocacy groups. Clare Murphy, head of public affairs at BPAS, has already been doing the rounds in the media claiming pills by post abortions are not only “safe” but “‘a phenomenal achievement” and “‘one of the health silver linings...of the pandemic”.

Without a swell of compelling counter information from members of the public and specialists, the government is likely to wave these new measures in without much scrutiny.  

This consulation gives us an unprecedented opportunity to expose the abortion industry, too long operating with impunity, and to provide facts and figures for politicians to draw upon if these measures result in a debate in the Houses of Parliament. 

Who should fill out this consultation? 

Everyone. The more people who express their disapproval of these new measures the better. As well as this it is worth noting that the consultation particularly welcomes views from those who have been directly affected by the “current temporary measures”, under this it specifies:

  • women and girls who have accessed abortion services during the COVID-19 pandemic and have taken both pills for EMA at home
  • healthcare professionals and National Health Service (NHS) organisations
  • NHS and independent sector abortion providers
  • Royal Colleges and other professional bodies

In light of this not only do we recommend that everyone fills it out, but that you also think carefully about anyone you may know who works in the healthcare industry, for the NHS, ambulance services, as a midwife, A and E nurse, or even persons that work in waste disposal or water treatment, or anyone who has had a medical abortion, and persuade them to offer their views too. If a wide range of professionals from various sectors speak up, this is bound to get the attention of policy makers. Think outside the box and be creative. 

How is the consultation structured?

The consultation consists of 10 questions asking about the impact of the “temporary measures” in the following areas:

  1. Safety
  2. Accessibility
  3. Privacy
  4. Impact on Abortion Providers
  5. Information to those taking the pills beyond 10 weeks
  6. Impact on NHS
  7. Safeguarding 
  8. Impact on communities
  9. Social Economic implications (i.e should these measures be kept on for poor people only?)
  10. Should temporary measures “become permanent” or “end immediately”

Points that need to be made and questions that need to be asked?

If you undertake this submission you will benefit from making the following points in your own words:

  1. The abortion industry have capitalised on Covid to push a long planned agenda
  2. The abortion industry don’t truly care about women’s health
  3. The abortion industry are down playing the impact of these pills for financial and ideological gain

Evidence for making these points:

The Abortion Industry have capitalised on Covid to push a long planned agenda

The NICE report in 2019 was already promoting telemed consultations before COVID. Unlike the current measures they insist that women who receive pills by post should attend a follow up appointment in person afterwards. The RCOG Guidance, first published shortly into lockdown, also promoted telemed abortion (without the follow up consideration) and was authored by major figures in the abortion industry including Dr Patricia Lohr (BPAS) and Dr. Jonathan Lord (Marie Stopes).  If telemed abortions were only designed to prevent the spread of COVID, why were they recommended before the virus even existed?

The Abortion Industry does not care about women’s health 

The survey conducted over June-July 2020 by a former Marie Stopes Director and consultant, revealed how easy it was to receive these pills after phone calls lasting as short as 29 minutes and 42 seconds. The survey also revealed women being sent pills after changing their baby’s gestational age, lying about their circumstances, and to aid in keeping a “beach body”.  If the abortion industry really cared about women’s health why are they not insisting on longer face to face consultations once lockdown ends?

The email from NHS England and NHS improvements to senior midwives detailed 13 serious incidences of “significant bleeding”, “major resusitations due to major hemorrhages”, “the delivery of infants up to 30 weeks gestation”, and at least one maternal death all resulting from the blind taking of abortion pills.  If the abortion industry really cared about women’s health why do they refer to these measures as “a phenomenal achievement” in the face of such tragedy? 

Freedom of Information requests from the DHSC detail 52 cases where women took these pills beyond the 10 week limit. We also know of a small number of cases which took place far beyond this cut off time; these include a child born at 28 weeks in the Midlands, another at 30 weeks, and another born at 32 weeks which was treated as a murder investigation (detailed in leaked email above). None of these were recorded in official statistics1

The statistics in question also make clear that “complications not reported prior to the completion of the abortion notification or that occured after discharge may not be recorded”2 hence the full carnage of these measures is far from being made known. 

If the abortion industry really cared about women’s health why have they enabled the illegal taking of pills, when before COVID this never happened, and why aren’t all the illegal incidences going on record?

  • Horrendous rates of serious side effects

According to the NHS these pills carry between 3-7% chance of failure (depending on gestation), by leaving baby body parts in the women (euphemistically described as “retained products of conception”). Of the estimated 46,000 DIY home abortions conducted since April there are likely to have been over 3000 such cases. Just two inner city hospitals reveal 14 women admitted for serious side effects. A significant number of which required blood transfusions, antibiotics and follow up surgical interventions. If the abortion industry really cared about women’s health why are they comfortable sending out pills with such a high rate of incomplete abortions?

NB: Incomplete abortion is not registered as a complication in formal statistics (see below).

The abortion industry are down playing the impact of these pills for financial and ideological gain.

  • Complication rates

Between 1 and 2 women per 1000 who undergo a medical abortion experience serious complications that require life saving treatment. These include: hemorrhaging, sepsis, uterine perforation and cervical tears.  Remarkably according to DHSC statistics, there has only been 1 complication from new pills by post measures between April and June. That is an astonishing 36 times lower than the normal yearly average. Does this mean less complications are taking place? Unfortunately not! If anything, with such a significant number of women taking these pills beyond 10 weeks, complication rates are likely to have risen not fallen. What this does mean is that under these new measures serious complications are not being picked up on the HSA4 form (Section 9), thus skewing the actual impact of these pills. If the abortion industry really cared about the impact of these new measures why don’t they insist on in-clinic follow up, delayed HSA4 form signing, and accurate recording of data. 

  • The financial gain from these new measures

Freedom of information requests from North Wales reveal abortion providers are charging the NHS £77 per phone consultation and £344.80 for the abortion pills. Therefore, the 46,000 DIY home abortions are estimated to have cost the NHS at least £19.4 million. This amount does not include all the additional costs to the NHS for women who experience further complications and long term health consequences from abortion. Considering the new measures allow fewer staff to perform more abortions in a shorter space of time, it is likely the abortion industry is cashing in big time from these measures, while totally avoiding the bill for all subsequent side effects (incomplete abortions) and other complications picked up by local hospitals. 

  • No NHS numbers

A further roadblock to assessing the full impact of these new measures is the lack of data on the women taking these pills. This is because NHS numbers are not mandatory on the HSA4 form. While abortion providers ask for NHS numbers they don’t insist apon them meaning, scientists and researchers cannot track the long term impact of these pills. Even if a person was ideologically committed to abortion, they should still, in the interests of health and science want to collect accurate data. The fact that the abortion industry are not, suggests they are more interested in sending out abortion pills than they are assessing the full long term impact the very same pills are having. Not only do these dangerous measures need to be stopped but new and tighter regulations need to be drafted to ensure proper data collection by abortion providers with tough fines for failing to do so.

You can fill out the Government Consultation here.

1 FOI 1250644, Tab name on supplementary information for DHSC, COVID Abortion Care

2 FOI 1260054, Tab name on supplementary information for DHSC, COVID Abortion Care