I am writing to express serious concern about the lack of transparency and undue haste surrounding the process by which the RCOG guideline ‘The care of women requesting induced abortion’ is currently being revised.
This RCOG guideline, which provides the basis for the ‘evidence-based counselling’ of women with crisis pregnancies was first published in 2000. An updated version followed in 2004 and that guideline served until this latest revision which took place during 2010.
This latest revision was prompted mainly by a recommendation of the House of Commons Science and Technology Committee which in 2007 had considered Scientific Developments relating to the Abortion Act 1967.
The latest revision (see draft) has been undertaken by a ‘multi-professional group’ which claims to be ‘supported by the Department of Health’. The group, as before, consists of representatives from the RCOG, the RCOG’s Faculty of Sexual and Reproductive Health (FSRH), the Royal College of General Practitioners (RCGP),and the abortion industry (namely the two largest abortion providers BPAS and Marie Stopes International).
The issues covered in the guideline are deeply controversial, are frequently in the news and have been the subject of recent debate in both Houses when the Human Fertilisation and Embryology Bill was under consideration in 2008.
The draft guideline as it stands draws a number of conclusions about fetal awareness, conscientious objection and long-term health risks of abortion (especially with respect to pre-term birth, mental illness and breast cancer) which I believe are inaccurate or over-simplified and are open to serious challenge on the basis of clinical and other evidence.
It also appears from p8 of the draft guideline that the RCOG may be intending to use it to put pressure on the government to liberalise the abortion law by regulation as opposed to by statute with respect to ‘home abortion’. This was made doubly clear by statements made by the British Pregnancy Advisory Service (BPAS) following their court defeat over ‘home abortion’ on Monday and is the tenor of a recent article by Zoe Williams in the Guardian.
It is therefore imperative that we get this right and do not rush it.
I have four main concerns about the process of consultation:
1.The lack of time available for consultation
According to the RCOG the draft guideline was posted on the RCOG website on 21 January. The deadline for responses is tomorrow18 February, leaving just 20 working days for stakeholders to make submissions. Following an intervention from your government after a parliamentary question by Nadine Dorries MP the RCOG have now agreed to accept submissions up until 25 February.
My understanding, based on enquiries amongst fellow MPs, leaders of stakeholder organisations, members and fellows of the Royal College and writers and researchers whose work is referred to in the document itself, is that very few people apart from those with a close connection to the abortion industry were aware of the consultation or the current peer review process.
Most now have very little opportunity to make a meaningful response by the deadline. In order to challenge the conclusions of the guideline before they are set in stone stakeholders require more time.
The Government Code of Practice on Consultation gives seven criteria that should be reproduced in consultation documents.
The first four of these do not appear to have been followed in this case. Specifically:
1. Formal consultation should take place at a stage when there is scope to influence the policy outcome.
2. Consultations should normally last for at least 12 weeks with consideration given to longer timescales where feasible and sensible.
3. Consultation documents should be clear about the consultation process, what is being proposed, the scope to influence and the expected costs and benefits of the proposals.
4. Consultation exercises should be designed to be accessible to, and clearly targeted at, those people the exercise is intended to reach.
2.Lack of transparency in the consultation process
This consultation appears to have been conducted in a way that gives stakeholders and peer reviewers little or no opportunity to influence the outcome in any meaningful way and I note that BPAS, one of the groups represented in the drafting group is already quoting the guidelines in the national press in a way that implies they have been finalised.
It seems also that the peer review process has been largely conducted as an ‘inside job’ with those on the committee contacting colleagues who most likely share similar views and would support their conclusions.
I note from the draft document (p12) that members of the drafting group itself, along with the DH and RCOG, suggested peer reviewers to consult and that the draft was also posted on the RCOG website and comments invited from ‘any member or fellow’.
The RCOG has been asked the following questions but so far no answers have been forthcoming:
1.Which individuals and organisations were formally notified about the consultation and when and how were they notified?
2.Which individuals were suggested by the DH and RCOG as perr reviewers and how and when were they notified?
3.How and when were fellows and members of the RCOG notified about the consultation other than by the document being placed on the College website?
3.Failure to consult with the Royal College of Psychiatrists
The Royal College of Psychiatrists in their Position statement on women's mental health in relation to induced abortion (14 March 2008) has indicated that there are significant mental health consequences of abortion for some women and is currently carrying out a major review of the literature which I believe is due to be completed this Spring. The guideline pre-empts this.
The RCPSych have also called for other colleges and professional bodies to incorporate this evidence into any guidelines for women considering abortion. This appears to be ignored by the RCOG guideline which fails to mention much of the recent evidence in this area, makes no reference to the RCPsych review or position paper and places an overreliance on a highly criticised review from the American Psychological Association.
4. Unbalance of the committee
The committee which has put the guideline together seems to be considerably unbalanced containing a significant number of people who might be said to have ideological and financial interests in abortion.
Of the 18 members I understand that eleven are identifiable as ‘pro-choice’ – most notably the representatives from Marie Stopes International and BPAS - two are members of the Department of Health, four are difficult to categorise, and one is a celebrity media doctor. A significant number of them receive payment for their involvement in abortion provision. There is notably no one with qualifications in mental health and no one from any group working to restrict abortion.
Committee members are as follows:
Professor Anna Glasier FRCOG (Chair), University of Edinburgh, RCOG nominee
Ms Toni Belfield, RCOG Consumers‟ Forum representative
Dr Sharon Cameron MRCOG, University of Edinburgh, RCOG nominee
Ms Joanne Fletcher, Royal College of Nursing nominee
Dr Katharine A Guthrie FRCOG, Faculty of Sexual and Reproductive Health Care nominee
Dr Sarah Jarvis, Royal College of General Practitioners nominee
Dr Patricia Lohr, British Pregnancy Advisory Service nominee
Ms Fiona Loveless, Marie Stopes International nominee
Dr Tahir Mahmood FRCOG, ex Vice President Standards
Dr Susan Mann, University College London, RCOG nominee
Dr R Kristina A Naidoo MRCOG, St Mary‟s Hospital, Manchester, RCOG nominee
Mr Kamal N Ojha MRCOG, St George‟s Hospital, London, RCOG nominee
Dr Kate Paterson, St Mary‟s Hospital, London, RCOG nominee
Dr Alison Richardson, Torbay Hospital, Torquay, RCOG nominee
Ms Jackie Routledge, North Lancashire PCT
Professor Allan Templeton FRCOG, University of Aberdeen, RCOG nominee
Ms Claudette Thompson, Department of Health
Ms Lisa Westall, Department of Health
These issues of process – a rushed consultation, lack of transparency, lack of wide consultation and unbalanced committee are very serious indeed and potentially a matter of huge potential embarrassment to the government at a time when we are trying to restore faith in official and parliamentary processes.
I would urge you as Prime Minister to request that:
1.The consultation period is lengthened to twelve weeks in accordance with the Government Code of Practice.
2.All RCOG College members and stakeholder individuals and organisations to be formally notified and invited to respond.
3.A full review of the committee membership be carried out focussing on their ideological and financial vested interests in abortion and in particular how much money each earns from abortion provision and that this information be made public.
4.An explanation be given as to why the Royal College of Psychiatrists has not been consulted in this review process nor their position even documented.
5.An explanation be given as to why no members of any groups ideologically opposed to abortion are represented on the committee or formally consulted.
6.An enquiry be carried out about the role of the main abortion providers and recipients of taxpayers money in this process (BPAS and MSI)
7.A full explanation be required form the RCOG with answers to the three questions posed under my second point above.
I would reiterate that I am most concerned about the lack of transparency in this consultation process and urge you to take steps to ensure that this clinical guideline undergoes proper peer review and that all stakeholders have an opportunity to contribute to the consultation.
I look forward to hearing from you at your very earliest convenience.