just released - consultation details on the new framework for abortion services in Northern Ireland - closing date 16th December 11.45pm gov.uk/government/con…
the government "welcome comments from anyone in Northern Ireland with an interest or view, particularly those directly impacted by the current law and any proposed changes and health professionals, to inform the shape of legislation to be introduced by 31 March 2020."
The document emphasises the consultation is **not** seeking views on whether the Secretary of State should be exercising this duty in the first place, the ethics of the matter of abortion, nor the abortion framework in England, Scotland or Wales.
Views are welcomed particularly from those directly impacted by the current law and proposed changes ... including healthcare professionals, Health and Social Care (HSC) Trusts in Northern Ireland and commissioners, independent sector abortion providers and Royal Colleges.
in terms of the specifics the options include allowing abortion up to 12 or 14 weeks gestation; without reason needing to be declared; without a medical certification as to gestation or limited form of certification, as to the gestation.
Post 12 weeks the document notes provision at this stage may be need for a number of reasons - relationship breakdown; delayed recognition of pregnancy; mental health issues, drug and alcohol dependency, homelessness and abuse ...
The document notes "issue of abortion time limits is highly sensitive, and the Government has not traditionally taken a view on how these should be set." it's then sets out a number of options ...
This includes no term limit "that an abortion can take place, where the physical or mental health of a woman or girl is at risk, up to the point where a fetus is capable of being born alive. Medical discretion would be used "taking account of the facts in each case"...
The document cautions though that this "would require a doctor to assess both the health of the pregnant woman or girl, and assess the viability of the fetus. This could require the doctor to make difficult and fine judgements and inconsistency in interpretation of viability" ...
The document suggests 2 options could be considered- up to 24 weeks gestation (23 weeks + 6 days) or 22 weeks (21 weeks + 6 days) depending on the individual circumstances of the woman and the fetus ...
the 22 week limit, is suggested based on advances in medicine and healthcare, where "it could be possible that a fetus having reached a gestation"...
In cases of severe or fatal fetal abnormality, the document notes that the Royal College of Obstetricians and Gynaecologists (RCOG) have provided guidance for health professionals on this issue ...
the document notes whilst abortion in these case most take place before 24 weeks, some do not, should abortions "without time limit should be provided in cases of FFA and/or where the disability is likely to have a profound impact on the length or quality of the child’s life"
The next stage of the document asks should abortion be provided, without a time limit where: There is a risk to the life of the woman/ girl greater than if the pregnancy were terminated? Termination is necessary to prevent grave permanent injury to the physical or mental health
In the section **who should perform abortions**, the document asks should a range of qualified health professionals be able to perform abortions - this would include for example doctors, nurses, midwives ...
In the section **where should abortions be performed**, the document asks should this include a range of settings. to allow for instance for the second stage of early medical abortion to occur in home settings ...
For abortions after 22/24 weeks of gestation, the documents asks should these only be provided by a Health and Social Care Trust provider in a hospital setting as more limited grounds apply after this gestation, the the risk of complications is higher ..
In terms of **certification of abortions after 12/14 weeks** the document asks should this be by two healthcare professionals or only one healthcare professional ....
The documents then moves on to **notification process** and asks should one be put in place to provide scrutiny of the services provided, as well as ensuring data is available to provide transparency around access to services?
On **conscientious objection** the document proposes refusal on conscience grounds should include the whole course of treatment for the purpose of the abortion but does not include any ancillary, administrative and managerial tasks that might be associated with that treatment.
It is noted that refusal of care cannot apply in emergency cases unless another qualified and experienced healthcare professional is immediately available and willing to participate in their place.
on **buffer zones** the document notes that new powers may be required in Northern Ireland to ensure that the new services can be provided and accessed in a way that protects women from harassment by anti-abortion protesters.
its is noted that protesters may cause distress, may prevent patients from accessing the healthcare services, whether this be abortion services or other healthcare services provided at the same location and may also be detrimentaldistressing for local residents and employees
such considerations will "need to balance rights and freedoms under the European Convention on Human Rights (ECHR), articles 9 (freedom of thought, conscience and religion), 10 (freedom of expression) and 11 (freedom of association) ...."
the document notes "interfering with those rights must be justified and balanced against the right to respect for private and family life under article 8 of the ECHR for those affected."...
on buffer zones the document asks "should there be a designated separate zone where protest can take place under certain conditions?"
To sum up the document proposes should new abortion services be provided without reason up to 12 weeks, 14 weeks, that post 12/ 14 weeks criteria could be applied; that a range of health professionals could provide abortions; range of settings could be used ....
... that conscience objection would apply to the direct abortion service but not indirect tasks; that buffer zones could apply; that designated protest zones could apply.
My first observations on what is missing - there is no consideration of monitoring refusal of care; telemedicine is not considered specifically, though 'flexibility' of provision is considered.
My first observations on the proposals overall - many model what is on offer elsewhere, there is an opportunity to use 'flexible' options re limits, providers, locations and push these to the **gold** standard of practice ... we have ample evidence to get this #nowforni
Another thought on refusal of care - lets flip that around - we need to consider health professionals who **conscientiously commit** to provide abortion care - these individuals should be provided with support and training as we move forward into a new system.
We know from studies elsewhere that professionals who **conscientiously commit** to provide abortion care can be stigmatised, isolated, silenced in workplaces because of their abortion work. We need to ensure that doesn't happen in Northern Ireland.
I will post key evidence to back up gold standard issues when I get a mo ...
