London, 18th January 2021
The UK Gov is seeking views on whether to make the choice of abortion telemedicine permanently available. Use our guide to submit your response.
Why is the UK government consulting on abortion telemedicine?
During the COVID-19 pandemic the government put in place a temporary measure in England, enabling women and girls to take both pills for early medical abortion (EMA) in their own homes up to 10 weeks’ (9 weeks and 6 days) gestation.
How can I help?
The government is now seeking views on whether to make the choice of telemedicine permanently available.
At this link you will find the key points of our response, and you can help too!
By responding to the consultation, you can help keep the option of telemedicine available permanently.
Home use of abortion pills for early medical abortion – UK Gov consultation
The consultation will close at 11:59pm on 26 February 2021.
Key points to bear in mind when responding to a consultation
- A consultation is not a referendum
Your submission should be evidence-based, focusing on policy impact. Evidence can include personal experiences.
Although public opinion matters, the main purpose of a consultation is to consider whether a policy proposal will work, and whether it will be cost effective, not whether it will be popular.
The best way to respond to the consultation itself is to give evidence about the policy impact.
TIP! This does not mean you must conduct academic research in order to respond; your own experiences are evidence too.
- Stick to the point
Make sure you read the call for evidence carefully, and respond to the question the policymakers are asking, not the question you believe they should be asking.
Do not be tempted to include calls for action on policy areas which fall widely outside the scope of the consultation, no matter how important those issues may be.
Your submission should be as succinct as possible. Don’t worry about including lots of background context; focus instead on what you have to say which is unique or significant.
TIP! Unless you are an industry expert with complex research to submit, two pages should be plenty of detail for most consultation responses.
- Never exaggerate
When writing a consultation response, it can be tempting to get caught up in the passions of persuasive argument, especially if the consultation is about an issue with which you have personal experience.
However, responses which are overloaded with emotional or political language are likely to be less impactful than responses which stick to provable facts and reasoning. The most important thing is to show how your recommended course of action meets the policymakers’ goals.
If you exaggerate, even indirectly, you risk discrediting your whole response by overstating your case.
TIP! Don’t make assertions (for example, “most women support this policy”) unless you have robust evidence behind them. If you use statistics or other people’s research, make sure you clearly reference the direct source material.
Abortion Telemedicine consultation: your guide to answering the questions
In a hurry? Remember, you do not have to answer every question. The last question is the most important one.
1. Question: 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?
Our answer:
a) Yes, it has had a positive impact
Points you may wish to consider in your comments:
- Abortion is a common and safe procedure. Serious incidents, events or complications are rare whether the patient is treated by telemedicine or not.
- Telemedicine has reduced the average gestational age at which abortion is carried out. Earlier abortions are the safest.
- When someone needs an abortion but is unable to visit a clinic in person, they often seek out abortion pills online. While pills purchased online aren’t always unsafe, it is true that the safest way to have an abortion is through a formal, regulated provider. Since the introduction of telemedicine in Britain, online abortion pill purchases have gone down.
- Staff are well-trained to recognise signs of risk over the phone, and there are processes in place to address any dangers, be they clinical (e.g. symptoms of an ectopic pregnancy) or personal (e.g. signs of domestic abuse).
- Ectopic pregnancies are unrelated to whether the patient has chosen an abortion or not. There is no clinical reason why everyone who wants an abortion should be forced to undergo a scan for an ectopic pregnancy while anyone wishing to continue their pregnancy should not.
2. Question: 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?
Our answer:
a) Yes, it has had a positive impact
Points you may wish to consider in your comments:
- For those with caring responsibilities, the ability to have an abortion from a formal, regulated provider at home has been more convenient.
- For people without their own transport, the ability to have an abortion from a formal, regulated provider in their own home has improved safety, and has been more convenient.
- Leaving the house to visit a clinic without the people you live with finding out where you’ve gone can be impossible.
- Transport and childcare are both expensive, and many people can’t afford to take time off work to travel for an abortion.
- Telemedicine has reduced waiting times, which in turn improves access. (It also improves safety, because earlier abortions are the safest.)
- Disabled people sometimes face barriers in attending services in person. By delivering abortion medication by post, telemedicine makes abortion more accessible for many disabled people. (For more on accessibility and inequalities, see Qs 8 and 9.)
3. Question: 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?
Our answer:
a) Yes, it has had a positive impact
Points you may wish to consider in your comments:
- It is very common to choose an abortion without telling anyone. Privacy can be an issue of personal safety, but even when it is not, people have a right to medical privacy.
- Visiting a clinic in person without telling anyone, especially household members, can be very difficult. Given the option, many people find it easier to receive medication privately at home than visit a clinic in private.
- With MSI UK, collecting the abortion medication in person is still an option where preferred. The important thing is that there is a choice, because everyone has different personal circumstances.
- Many abortion facilities around the UK face anti-choice demonstrators outside. Behaviours include harassment, praying, shouting, spitting and taking photographs. This is a major threat to privacy which telemedicine helps avoid.
- Abortion medicine is delivered in plain, non-conspicuous packaging. All communication is carried out with utmost respect for privacy; for example, we will never say where we are calling from on the phone until we are certain we are speaking with the right person.
4. Question: 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.
Our answer:
a) Yes, it has had a positive impact
Points you may wish to consider in your comments:
- Telemedicine has been extremely beneficial for those involved in delivering abortion services.
- It allows frontline health and social care staff to dedicate resources to the patients who need them most.
- Resources are not wasted on fulfilling arbitrary requirements with no clinical basis (for example, ectopic pregnancy scans for every single person seeking an abortion).
- By reducing waiting times, telemedicine improves clinical outcomes, because earlier abortions are the safest.
5. Question: Have other NHS services been affected by the temporary measure?
Our answer:
a) Yes, it has had a positive impact
Points you may wish to consider in your comments:
- There is a long-term impact on the wider health and social care system if people are unable to access abortion.
- Pressures have been eased on NHS providers because telemedicine has been efficient.
6: Question: 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?
Free comments:
Points you may wish to consider in your answer:
- There is a very low risk of mistakes being made about the gestational age of a pregnancy, but usually it is reliable to calculate this based on the last period cycle.
- When human error does occur, it may be found that a pregnancy is further along than was initially believed. Should this happen, it is unlikely that there would be medically significant consequences.
- The possibility for error should be discussed, so that decisions are always made in good faith, and so that the person accessing the abortion knows their rights if a mistake is made.
- It should also be made clear to any staff involved in delivering abortion care that mistakes can happen in good faith, and that in the event of a mistaken gestation date, the best practice approach would be to offer support, not judgment or (as can happen in extreme cases) criminalisation.
- NB: in Scotland, the government does not force a standardised gestation limit on all patients, but rather, allows clinicians to decide this directly with their own patients on a case-by-case basis. MSI UK supports this approach.
7. Question: 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?
Our answer:
a) Disadvantages
Points you may wish to consider in your comments:
- Health assessments by phone are very common. It is accepted as clinically safe for many other types of care. Abortion is a safe and common procedure, and there is no clinical reason why a face-to-face assessment should always be needed.
- It is a matter of personal choice whether to receive abortion medication in the post or whether to collect it in person.
- Home deliveries are sent securely, in non-conspicuous packaging.
- MSI UK runs a 24-hour aftercare line, an anonymous online chat tool, and online information. Our team members are trained to recognise clinical and safeguarding risks without face-to-face contact.
- We, like other providers, work closely with social workers, police, the NHS and anti-violence against women groups to make sure that any dangers are escalated at once.
- Far from improving safety, by forcing everyone who needs an abortion to visit a clinic in person, the law creates a very real safety concern for those living with abusive partners, families, or other household members.
- Choice is about more than simply the right to choose an abortion. It means that for some patients, surgical abortion will be the right option, for others, telemedicine with an in-person collection option will be more appropriate, and for some, the most suitable option will be receiving medication in the post.
Public sector equality duty
8. Question: 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 of being able to take both pills for EMA at home on people with a disability or on people from different ethnic or religious backgrounds?)
AND
9. Question: 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?
Free comments:
Points you may wish to consider in your answer:
- Sex is a protected characteristic. Abortion has long been stigmatised because it is a service associated with women. Telemedicine provides greater dignity, privacy, safety and choice for all our patients, the majority of whom are women.
- Age is a protected characteristic. Young people are often dependent on parents or caregivers for transport. Access to essential medical services like abortion shouldn’t be conditional upon the values or emotions of the adults in a young person’s life.
- Disability can make it difficult to access health services in person, and abortion is no exception. Home delivery makes abortion more accessible for people with disabilities.
- Anti-choice groups often target those accessing an abortion clinic in person. While it can be distressing for anyone to receive this type of harassment, it can be disproportionately distressing for people who are already marginalised by a protected characteristic, such as people of colour, religious people, teenagers, trans or non-binary people, disabled people and people with mental health problems. Many people accessing abortion have experienced rape, abuse or assault. Anti-choice harassment outside clinics can be a trigger for Post-Traumatic Stress Disorder. Telemedicine allows people to avoid this harassment.
- Telemedicine has been beneficial for transgender men and non-binary people who choose an abortion. We know that the experiences of trans men accessing health care services generally associated with women, such as abortion are often reported to be painful, humiliating, or confusing. Being able to access an abortion remotely gives transgender men and non-binary people safety, privacy and dignity when accessing these services.
- We know that travel is costly and difficult, and that it is real barrier for lower income individuals accessing care safely, confidentially, or comfortably. Telemedicine removes this barrier.
- Childcare is expensive, and many people cannot afford to take time away from work to travel for an abortion – especially as many people, quite understandably, may not feel comfortable explaining the medical reason (an abortion) to their employer. Telemedicine removes this barrier.
Whether to make home use of both pills for EMA a permanent measure
10. Question: Should the temporary measure enabling home use of both pills for EMA [select one of the below]
a) Become a permanent measure?
b) End immediately?
c) As set out in the current temporary approval, be time limited for 2 years or end when the temporary provisions of the Coronavirus Act 2020 expire, whichever is earlier?
d) Be extended for one year from the date on which the response to this consultation is published, to enable further data on home use of both pills for EMA and evidence on the temporary approval’s impact on delivery of abortion services to be gathered?
e) Other [please provide details]?
Our answer:
a) Become a permanent fixture
MSI UK’s experience of providing telemedicine in England has shown the current arrangements to be safe, convenient, accessible and to have reduced waiting times.
We strongly support the retention of telemedicine abortion as an option after the COVID-19 pandemic is over.
- For points you may wish to consider in your answer, read our blog “UK Government Telemedicine Consultation: our response and recommendations“.
Ready to submit your response? The consultation will close at 11:59pm on 26 February 2021.
Follow this link: Home use of abortion pills for early medical abortion – UK Gov consultation
