The much anticipated and long overdue Women's Health Strategy for England was finally published by the UK government last week (see BioNews 1152). Having submitted a detailed response to the government's call for evidence relating to the strategy, and having also recently published our own report on public views of this area, we at the Progress Educational Trust (PET) were very keen to see what the Strategy would say.
The press release that accompanied the Strategy promised that 'women and girls across England will benefit from improved healthcare following the publication of the first ever government-led Women's Health Strategy for England'. The big question we had was, how will this help women who need to access fertility treatment?
So we scrolled through to section 12 of the Strategy, which covers 'Fertility, pregnancy, pregnancy loss and postnatal support'. One of the 'ten-year ambitions' in this section is that:
'Over the life of this strategy, we will work with NHS England to address the current geographical variation in access to NHS-funded fertility services across England. Female same-sex couples are able to access NHS-funded fertility services in a more equitable way. There is an end to non-clinical eligibility criteria, through an assessment of current criteria and updated commissioning guidance. There is improved evidence-based information about privately funded fertility treatment "add-ons" so patients are better able to make informed choices.'
Which is all well and good, but how is this to be achieved? The detail is somewhat sparse.
PET warmly welcomes the commitment to remove non-clinical access criteria to fertility treatment, such as one partner having a child from a previous relationship. This is an issue which PET has brought to the attention of at least half a dozen health ministers over the years.
There is also good news in the Strategy for female same-sex couples, who will no longer be required to pay for artificial insemination to prove their fertility status. NHS treatment for female same-sex couples will start with six cycles of artificial insemination, prior to accessing IVF services if necessary.
There is a commitment in the Strategy to explore mechanisms for publishing national data on the provision and availability of IVF, in the interests of greater transparency. This is good news for organisations that have previously taken on the job of collecting such data – chiefly PET, Fertility Network UK and the British Pregnancy Advisory Service – because this is tedious and painstaking work which consumes a lot of staff time.
However, much as we welcome the news that it will no longer fall to charities to do this, we would still prefer it if the taxpayers' money about to be allocated to this was spent instead on providing a few dozen (maybe even more) precious cycles of IVF.
As for doing anything to actually tackle the postcode lottery for NHS-funded fertility treatment, the Strategy falls down completely. There is a reference to the fact that the National Institute for Health and Care Excellence (NICE) is updating its fertility guideline, and is currently reviewing whether the guideline's recommendations for access to NHS-funded treatment are still appropriate. The NICE website does not have a publication date (or indeed very much detail at all) about this project, but the Strategy notes that the new NICE guideline is expected in 2024.
What is conspicuous by its absence is any commitment to enforce the new guideline once it is published, or even to adopt a phased implementation plan.
PET has been surprised by the positive reaction that the Strategy has received from some quarters. Few have remarked on the key thing that is missing from the Strategy – in a word, money. There is no commitment to provide the money (which is tiny in health budget terms) to fund equitable access to fertility treatment, in accordance with the current or forthcoming NICE guideline.
The postcode lottery will not be ended by transparency. This postcode lottery has generated more headlines and media appearances than pretty much anything else we have worked on at PET during the last 15 years. It is not a secret. Changing who gathers and publishes the data will not give a single woman a new opportunity to try for a baby.
Our recent report Fertility, Genomics and Embryo Research: Public Attitudes and Understanding, which collects nationally representative research commissioned by PET and conducted by Ipsos, shows that two-thirds of the public support the provision of NHS-funded fertility treatment to people who are infertile (see BioNews 1148).
We cannot improve upon the words of the world's first IVF baby Louise Brown (who turns 44 today), who contributed her own comment to this section of our report. She says: 'It is time to end the postcode lottery for fertility treatment. For people who don't have much money and desperately want a child, being told "We won't fund your IVF treatment" must be devastating.'
Some of the other commitments (such as they are) in the Strategy left us thinking 'but shouldn't you be doing this anyway?'. For example, updating the NHS website on fertility, and improving signposting to the HFEA website.
As for the more concrete commitments in the Strategy, such as removing non-medical eligibility criteria, what is their status? Will it be mandatory for commissioners to remove such criteria from their policies? If so, when? How, and by whom, will this be enforced?
One might expect the concluding section of the Strategy, on 'Implementation and monitoring progress', to answer such questions. This section is heavy on management speak heavy but light on detail. So we will have to wait and see.
One glimmer of hope is that the formidable Professor Dame Lesley Regan has been appointed as the Women's Health Ambassador. PET hopes that she can not only deliver the report's ambitions and commitments, but improve upon them, and persuade whomever is in government to fund fertility treatment properly and end the postcode lottery once and for all.