Consultation outcome

Home use of both pills for early medical abortion (EMA) up to 10 weeks gestation: summary of consultation responses

Updated 10 March 2022

Introduction

Background to the consultation

During the coronavirus (COVID-19) pandemic the government put in place a temporary approval in England, enabling women to take both pills for early medical abortion (EMA) up to 10 weeks (9 weeks and 6 days) gestation in their own homes, following a telephone or e-consultation with a clinician, without the need to first attend a hospital or clinic. This measure was put in place on 30 March 2020 to reduce the risk of transmission of COVID-19 and ensure continued access to abortion services. It expires on 30 March 2022 or when the temporary Coronavirus Act provisions end, whichever is earlier. Prior to the temporary approval, women were required to attend a clinic to take the first EMA pill and had the choice of taking the second pill at home or in the clinic.

Following a commitment made in Parliament to consult on whether to make the temporary approval permanent, the government sought views on this issue. The government recognises the sensitivities around abortion and the strongly held views on all sides of the debate. This is why we consulted to give everyone an opportunity to input views, evidence and data.

The consultation sought views on whether to make the current temporary approach permanent or revert to the previous position. It also sought views on whether to extend the temporary approval for a further period of one year.

How we consulted

The consultation ran for 3 months, opening on 26 November 2020 and closing on 26 February 2021. It was publicised on the department’s social media channels and stakeholders were informed by email. The consultation was hosted online, accessible via GOV.UK. Respondents had the option to respond to the consultation online, including email, or via post.

Responses to the consultation questions were analysed using quantitative and qualitative methods. The quantitative analysis was carried out independently and the qualitative analysis was undertaken by the Department of Health and Social Care (DHSC). Key findings for each of the consultation questions have been set out in this response.

In the consultation document we set out that we particularly welcomed views from those who have been directly affected by the current temporary measure, including:

• women 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

It is important to note that views gathered through a public consultation should not necessarily be considered as representative of the views of the wider population. Rather, they are the views of a self-selecting group of people who were aware of the consultation, have an interest in the subject matter, and chose to take part. The approach to the analysis took account of the range of responses received on the consultation platform and the postal and email submissions.

Submissions received

We received a total of 18,834 responses to the consultation.  The majority of the responses (18,717) were submitted through the online consultation portal, with a relatively small number (117) received via post or email.

There were 18,659 individual and 175 organisational responses. Of the individual responses, nearly half (9,109) were from individuals affiliated to campaigns and the majority of these (8,424) associated with one campaign. Campaign responses are based on a standard template or ‘stock response’ provided by a campaign organiser, and then submitted either via the online portal, or by post. Although campaign responses were predominantly submitted by individuals, there were a small number submitted by organisations. In these campaign responses, respondents could add their name and contact details and additional comments to a standardised response, and then submit this as their response.

For analytical purposes, responses affiliated to a campaign (where there was some form of standardised response) were recorded as individual responses and were analysed in the same manner as all other responses. The patterns of responses varied when campaign responses were considered separately (please see the annex below for more details). The number of responses and organisations are also detailed in the annex.

Summary of responses to each question

Impact of home use of both pills for EMA up to 10 weeks gestation on delivery of abortion services

The consultation asked a series of questions on the impact of the temporary measure enabling home use of both pills for EMA.

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 a particular regard to safety?

Impact	All responses
Positive	25%
No impact	1%
Negative	69%
I don’t know	5%

The majority of all respondents (69%) stated that the temporary measure has had a negative impact on the provision of abortion services for women accessing these services. There were a number of concerns raised about safety, the most common of which was the risk of women being coerced into an abortion when they are not physically being seen in a service. Concern was also expressed that gestation may be inaccurately assessed and about the absence of support particularly in relation to management of emotional distress.

Responses from abortion providers and professional bodies highlighted research from February 2021 showing that the temporary approval has provided safe and effective care for women. Eighty-three per cent of women who responded to the consultation and who had used both pills for EMA said that the temporary approval has had a positive impact on safety. Some respondents highlighted that an EMA at home model improves safety by facilitating access to legal, regulated abortion services for those who would otherwise rely on illegal online providers of abortifacients (an agent such as a drug, which induces abortion).

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 a particular regard to accessibility?

Impact	All responses
Positive	26%
No impact	1%
Negative	62%
I don’t know	11%

The majority of respondents (62%) considered that the temporary measure has had a negative impact on the provision of abortion services for women accessing these services and a negative impact on accessibility to services. The most frequently mentioned was concern about reduced access for those with mental health conditions. Other concerns included increased risk to women living in rural communities who do not have easy access to critical care services and vulnerable women being rushed through the abortion process.

Responses from clinical commissioning groups (CCGs) and NHS trusts were positive about the benefits for women but also highlighted concerns about increased safeguarding risks – for example, for people with learning disabilities.

A number of responses highlighted that the removal of the need to travel to clinics had improved access to services for women. Eighty-five per cent of women who had accessed abortion service during the pandemic and had used both pills for EMA thought that the temporary measure has had a positive impact on accessibility. Other benefits mentioned in responses include reduced waiting times, reduced gestation at which abortions are taking place and more flexibility for women on when pills can be taken (for example, arranged around childcare responsibilities or working hours). Responses from abortion providers highlighted reduced waiting times and reductions in average gestation that had occurred since the temporary approval had been introduced. Abortion providers also pointed to an analysis of patient reported outcomes that had found that 66.3% of patients saying that they would prefer telemedicine even if COVID-19 was not a factor and that patients rate home use highly.

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 a particular regard to privacy and confidentiality of access?

Impact	All responses
Positive	25%
No impact	2%
Negative	64%
I don’t know	9%

The majority of respondents (64%) stated that the temporary measure has had a negative impact on the provision of abortion services with regard to privacy and confidentiality of access. Respondents who had concerns about privacy and confidentiality highlighted that not attending a clinic would miss opportunities to identify domestic abuse or coercion. Respondents also said that privacy and confidentiality could not be guaranteed. There were also concerns that home use increases the risks of pills being obtained fraudulently and beyond the gestational limit permitted.

Those who felt that the temporary measure had positive impacts in relation to privacy and confidentiality of access considered that home use meant women did not have to face protests outside clinics which can be upsetting. The removal of the need to disclose journeys to colleagues or family was also seen as a positive impact, allowing more privacy. Eighty-one per cent of women who had accessed abortion services during the pandemic and had used both pills for EMA thought that it has had a positive impact on privacy and confidentiality.

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, and so on.

Impact	All responses
Positive	23%
No impact	1%
Negative	55%
I don’t know	21%

The majority of respondents (55%) considered that the temporary measure has had a negative impact on the provision of abortion services for women accessing these services. Responses expressed concern that it had led to less accountability for abortion providers, staff were less able to ensure that safeguarding were being adhered to and women were not being placed at the centre of care.

Reponses from abortion providers and professional bodies reported that the temporary measure increased efficiency and flexibility in providing abortion services. They stated that telemedicine is lower cost than in-person care and there is more workforce flexibility as staff can work from home. Providers also reported that the measure has enabled them to spend more time with patients who need in-person care. 

Many of these benefits were highlighted in the responses from CCGs and NHS trusts. But at the same time some also stressed that patient safety and safeguarding must be prioritised, because without a robust process to identify those who need face-to-face appointments, the system is open to exploitation or abuse and could contribute to unsafe practice.

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

Affected	All responses
Yes	55%
No	8%
I don’t know	37%

The majority of respondents (55%) stated that other NHS services have been affected by the temporary measure although just over a third (37%) responded that they did not know. Some respondents from CCGs and NHS trusts reported that the temporary measure had increased presentations to emergency departments and that other general hospital services, such as ambulance services, had been impacted by the temporary measure. Some responses from providers and professional bodies commented that the shift towards more EMA had reduced the demand for surgical procedures, leading to fewer complications and freeing up NHS capacity.

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?

There was a broad range of responses to this question.  Some respondents considered information should be provided on:

• increased risks and reduced efficacy of EMA at later gestations

• risk of death

• risk of ongoing viable pregnancy

• risk of mental health complications

• counselling

• risk of committing a criminal offence if the pills are taken at gestations beyond 10 weeks

Women who had accessed abortion services during the pandemic and had taken both pills for EMA said that information should be provided on:

• the risks of accessing pills over 10 weeks gestation

• whether a scan may be necessary

• how inaccurate dating of pregnancy may mean increased pain and bleeding

CCGs, NHS trusts, abortion providers and professional bodies responded that:

• services should work to Royal College of Obstetricians and Gynaecologists (RCOG), Faculty of Sexual Reproductive Health (FSRH) and Royal College of Midwives (RCM) guidance on abortion services during the COVID-19 pandemic

• risks of using pills after 10 weeks needs to be explained (alongside other medical risks)

• all risks and benefits based on best evidence should be shared with the woman

• information on who to contact for further information or advice on how to seek emergency medical help should be provided

• clinical teams are best placed to determine what they need to discuss with their patients

Abortion providers also commented that the:

• government should not be mandating provision of particular information

• gestational limit of up to 9 weeks and 6 days in the approval should be removed entirely

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?

Impact	All responses
Benefits	78%
Disadvantages	13%
No	3%
I don’t know	6%

The majority of respondents (78%) considered that there are benefits in regard to safeguarding in requiring women to make at least one visit to the clinic. Respondents highlighted the benefits in requiring women to make at least one visit to a service to be assessed by a clinician. They also expressed concern that being certified for an abortion without seeing a doctor in person increases risks of potentially life-threatening conditions being missed, pills being prescribed beyond the 10-week limit, more women being coerced into a home abortion against their wishes and pills being obtained fraudulently.  

Forty-five per cent of the group of women who had accessed abortion service during the pandemic and had used both pills for EMA felt that there were benefits in relation to safeguarding and women’s safety in requiring at least one visit to a service to be assessed by a clinician, with 22% saying that there would be disadvantages.

Safeguarding organisations responded that there are very significant advantages for all those aged under 18, and those under 25 who are care experienced, to be seen at least once for an assessment by a clinician. They also expressed the view that face-to-face clinical assessment reduces the risk from those who sexually exploit children, manipulate the system or force their victims to obtain an abortion. Some individual health professionals reported that safeguarding is improved when patients are seen in person. 

Other respondents highlighted that women experiencing domestic abuse or sexual violence may not be able to leave home or travel to in-person services. A blanket requirement for women to make at least one visit to a service may result in women who struggle to access regulated, safe abortion services turning to unregulated services instead. 

Abortion providers and some other respondents commented that safeguarding can be successfully carried out remotely and some women may find it easier to talk about their experiences over the telephone. It was acknowledged that for some women, it may be more beneficial for them to attend a clinic environment, in particular if there are safeguarding issues such as domestic abuse – however, this should be part of the offer rather than compulsory. 

Public sector equality duty

As part of the consultation, we invited views on the impact of making home use of both pills for EMA permanent on people with protected characteristics. We also invited views on the steps that could be taken to mitigate against any adverse impacts.

Under the Equality Act 2010, the protected characteristics are:

• age

• gender reassignment

• being married or in a civil partnership

• being pregnant or on maternity leave

• disability

• race including colour, nationality, ethnic or national origin

• religion or belief

• sex

• sexual orientation

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?

Responses received highlighted a mixture of differing impacts on groups of people and communities. Some responses highlighted concerns about staff with an objection to abortion being asked to take on a wider range of tasks, such as posting pills. They also raised concerns about the risk of women with learning disabilities or who do not speak English struggling to understand information relating to the risks involved.

A number of responses raised concerns about the impact on under 18s in relation to safeguarding risks. There was also concern about missed opportunities for an enhanced discussion regarding informed choice and signposting to support services. 

Abortion providers and professional bodies considered that home use has had a positive impact on groups with the following protected characteristics:

• sex
• age (young people may not be able to access clinics)
• disabled women
• lesbian, gay, bisexual and transgender (LGBT) people
• victims of sexual or domestic violence or abuse
• teenagers
• women from deprived areas
• black, Asian and minority ethnic (BAME) and migrant women
• homeless women
• women with mental health or substance use issues
• women with insecure immigration status who may experience difficulties accessing in-person services

Responses also highlighted that the costs of travel and childcare are barriers to accessing in-person services and have a greater impact on women facing multiple deprivations and discrimination. 

Socio-economic considerations

The consultation also sought views on the potential for making permanent home use of both pills for EMA to reduce or increase inequality in health outcomes experienced by different socioeconomic groups.

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?

Some respondents expressed concern that equal access to what they consider a highly risky procedure is an inappropriate measurement of socio-economic success or equality. In addition, they considered there was a risk that home use will be promoted as being especially important for women in deprived areas rather than prioritising investment in improving conditions for women in more deprived areas.  

Other respondents also identified positive benefits and highlighted their view that the temporary approval has reduced socio-economic inequalities for women from more deprived backgrounds and for women from more rural areas, who has previously experienced longer waiting times and later gestation at treatment. 

Other positive impacts cited in responses were that the high cost of childcare, cost of travel to clinics and having to request time off work had previously created a higher barrier to access services for the most disadvantaged. 

Whether to make home use of both pills for EMA a permanent measure

As set out above, the current approval allowing home use of both pills for EMA up to 10 weeks gestation will currently expire on 30 March 2022 or when the temporary Coronavirus Act provisions end, whichever is earlier. The consultation sought views on whether this should be made permanent (noting that, as with any other healthcare service, the measure would be kept under review should new evidence or information emerge) and, if not, when the temporary measure should end.

The consultation set out that the options for the future of the temporary measure set out in question 10 will be subject to any considerations regarding the COVID-19 pandemic that are relevant at the time the decision is taken.

Question 10: Should the temporary measure enabling home use of both pills for EMA:

• become a permanent measure?

• end immediately?

• 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?

• 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?

• other?

Answer	All responses
End immediately	70%
Become a permanent measure	22%
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	4%
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	3%
Others	1%

The majority of respondents (70%) stated that the temporary measure enabling home use of both pills for EMA should end immediately. Some respondents said that it should be removed for the safety reasons highlighted above in response to the other questions asked in the consultation document. Health professional organisations, abortion providers and some other organisations were in support of the temporary measure becoming permanent also for the reasons documented above. There were mixed views from CCGs and NHS trusts. Safeguarding organisations stated that it should be removed for those who are under 18 and those who are care experienced and under 25.  

Conclusion

The purpose of this report is to present and summarise the responses to the consultation.

We thank all individuals and organisations who have taken the time to submit their views as part of the consultation.

The government recognises the sensitivities around the issue of abortion and the strongly held views on all sides of the debate. Safety and continued access to abortion is our priority and will remain so.  

Annex

Campaign responses received

Campaign	Number
Right to Life	8,424
Society for the Protection of Unborn Children	288
British Pregnancy Advisory Service	240
Christian Concern	84
Doctors for Choice UK	23
MSI reproductive choices	19
Abortion Rights	13
Centre for Bio-Ethical Reform UK	10
Life Charity	5
Decolonising Contraception	3

Summary of consultation questions by campaign and non-campaign responses

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 a particular regard to safety?

Impact	All responses	Non-campaign responses
Positive	25%	45%
No impact	1%	2%
Negative	69%	45%
I don’t know	5%	7%

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 a particular regard to accessibility?

Impact	All responses	Non-campaign responses
Positive	26%	32%
No impact	1%	2%
Negative	62%	49%
I don’t know	11%	17%

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 a particular regard to privacy and confidentiality of access?

Impact	All responses	Non-campaign responses
Positive	25%	46%
No impact	2%	4%
Negative	64%	33%
I don’t know	9%	17%

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, and so on.

Impact	All responses	Non-campaign responses
Positive	23%	44%
No impact	1%	2%
Negative	55%	18%
I don’t know	21%	18%

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

Affected	All responses	Non-campaign responses
Yes	55%	21%
No	8%	14%
I don’t know	37%	65%

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?

Benefits or disadvantages	All responses	Non-campaign responses
Benefits	78%	61%
Disadvantages	13%	21%
No	3%	6%
I don’t know	6%	12%

Question 10: Should the temporary measure enabling home use of both pills for EMA:

• become a permanent measure?

• end immediately?

• 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?

• 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?

• other?

Answer	All responses	Non-campaign responses
End immediately	70%	45%
Become a permanent measure	22%	41%
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	4%	8%
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	3%	5%
Others	1%	1%

List of organisational responses

• Abortion Rights

• Abortion Support Network

• Affinity

• Affinity Financial Advisors

• Alliance for Choice

• Antioch Community Church Sheffield

• APPG on Population, Development and Reproductive Health

• ARCH (Abortion Recovery Care and Helpline)

• Birmingham and Solihull Women’s Aid

• Birthrights

• Brephos

• British Medical Association

• British Pregnancy Advisory Service

• British Society of Abortion Care Providers

• Brook

• Cardiff University Students’ Union Pro-Choice Society

• Catholic Medical Association (UK)

• Centre for Bio-Ethical Reform UK

• Christ Church Exeter

• Christian Concern

• Christian Medical Fellowship

• Christian Party

• Christian Peoples Alliance

• Christians in Pharmacy

• Choice

• Daybreak Ministries

• Doctors in Unite

• Doctors for Choice UK

• Dovecot Evangelical Church

• East Berkshire CCG

• End Violence Against Women Coalition

• EPC

• Family Education Trust

• Fareham SE Hants and Gosport CCG

• FiLiA Charity

• First Steps PreSchool International

• Free Presbyterian Church of Ulster

• Gateway Church Wirral

• Gunnersbury Baptist Church

• Hampshire Hospitals Foundation Trust

• Helena Kennedy Centre for International Justice, Sheffield Hallam University

• Her Voice

• Hope Church

• Human Developmental Biology Resource

• Humanists UK

• International Federation of Gynaecology and Obstetrics

• International Planned Parenthood Federation

• JCSofGS

• Life

• Lighthouse Church

• Liverpool CCG

• London Borough of Lambeth

• London School of Hygiene and Tropical Medicine       

• Maternity Action

• Medical Women’s Federation

• Mission and Public Affairs Division, Church of England

• MSI Reproductive Choices

• National Education Union

• National Network of Designated Healthcare Professionals for Safeguarding Children

• National Secular Society

• National Unplanned Pregnancy Advisory Service (NUPAS)

• New Life Church

• New Generation Church

• Newcastle University

• NHS Doncaster CCG

• NHS East Berkshire CCG

• North Central London CCG

• North East Sexual Health Commissioners Network

• North West Pro-Life

• NUS UK

• PANDAS Foundation

• Percuity Limited

• Post Abortion Support for Everyone

• Portsmouth CCG

• Portsmouth City Council Children’s Services Directorate

• Portsmouth Hospital University Trust

• Pregnancy Sickness Support

• Priory Medical Group

• Pro Life Southampton

• Project Truth UK

• Public Health Portsmouth, Portsmouth City Council

• Rachel’s Vineyard Birmingham

• Reclaim Rosslyn Road

• Redeemer Church, Chester-le-Street

• Regent Christian Fellowship

• Reproduction, Sexualities and Sexual Health Research Group, the Open University

• Richmond abs

• Royal College of Midwives

• Royal College of Nursing

• Royal College of Obstetricians and Gynaecologists

• Royal Cornwall Hospitals NHS Trust

• Royal Pharmaceutical Society

• Safe Abortion Action Fund

• Skelmersdale Baptist Church

• Sky News

• Sister Supporter

• Society and College of Radiographers

• Society for the Protection of the Unborn Child

• Solent NHS Trust

• South Tyneside CCG

• Southall Black Sisters

• Southampton City CCG

• Spring Road Evangelical Church

• St Anselm’s Pro-life Group

• St Johns Wimborne

• Stonewall

• Support 4 the Family in UKIP

• Sussex CCG

• The Alliance of Pro-life Students

• The Anacombe Bioethics Centre

• The Christian Institute

• The Evangelical Alliance

• The Faculty of Sexual and Reproductive Healthcare

• The Hope Centre

• Trinity Grace Church, Ramsbottom

• Unite retired members’ branch Croydon

• Unity Sexual Health

• University Hospitals Bristol and Weston NHS foundation trust

• Vagina Museum

• Voice for Justice UK

• Wesleyan Reform Union Christian Ethics and Social Action

• West Hampshire CCG

• Women on Web

• Women’s Aid Federation of England

• Woman’s Place UK

• Wotton Baptist Church