FOI 9559 internal review – clarification and supplementary point regarding PMA / A-EQUIP records

This Freedom of Information request asked Gloucestershire Hospitals NHS Foundation Trust for records relating to A-EQUIP and Professional Midwifery Advocate involvement in the decision to suspend the home birth service.

The Trust’s response stated that no relevant records were held.

This matters because the Trust’s own home birth suspension risk assessment refers to PMA restorative clinical supervision / support as part of the controls around the risks created by the suspension and wider maternity staffing pressures.

That raises an important question:

If PMA / A-EQUIP support was being relied on as a governance, staff wellbeing, culture, or risk-control measure, where are the records showing how that support was considered, escalated, assessed, or implemented?

I have therefore asked for this FOI response to be reviewed. The internal review asks the Trust to explain whether it searched PMA records, A-EQUIP documentation, supervision records, staff wellbeing escalation records, maternity safety culture records, governance papers, leadership emails, and Datix-linked staff safety or wellbeing discussions.

This is not just about whether a document can be found. It is about whether the Trust can properly evidence the governance controls it says were in place during the suspension of a lawful maternity choice.

The original FOI response is published below so that this process is visible and open to public scrutiny.

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Dear Vanessa,

Apologies for the delay in replying to your email of 16 March. Thank you for clarifying that FOI 9559 is already under internal review.

I can confirm that I am referring to FOI 9559.

I would also like to add a supplementary point to the internal review, as I now have further relevant information from the Trust’s own home birth suspension risk assessment.

In the response to FOI 9559, the Trust stated that no records were held in relation to A-EQUIP / Professional Midwifery Advocate correspondence, assessments, governance discussions or related documentation connected to the suspension of the home birth service.

However, the Trust’s “Suspension of Home Birth Service Risk and Impact Assessment” appears to reference PMA restorative clinical supervision / support as part of the existing or planned controls relating to the risks created by the suspension and/or maternity staffing pressures.

This creates an important inconsistency.

If PMA restorative clinical supervision, PMA support, or A-EQUIP-type processes were being relied upon as a governance, safety, staff wellbeing, culture, or mitigation control, then I would expect there to be some form of record showing:

• how that control was identified;

• who was responsible for it;

• whether PMAs were consulted;

• whether any staff wellbeing or safety concerns were escalated through PMA/A-EQUIP routes;

• how the effectiveness of that control was assessed;

• whether this was reported through maternity governance structures.

For the internal review, please could the Trust specifically confirm whether searches were carried out across the following areas:

• PMA records;

• A-EQUIP implementation documentation;

• restorative clinical supervision records or summaries;

• staff wellbeing escalation records;

• maternity safety culture records;

• maternity leadership emails involving PMAs;

• Datix-linked staff safety, staffing, culture or wellbeing discussions;

• Perinatal Board papers;

• Divisional Board papers;

• Women and Children’s governance papers;

• any records where PMA support was discussed as a mitigation, control, or response to the home birth suspension.

If no records are held in any of these areas, please could the internal review explain how PMA restorative clinical supervision / A-EQUIP support was being used or cited as a governance control in the risk assessment without any corresponding records, correspondence, assessment, escalation, or governance documentation.

To be clear, I am not only asking for records to be located. I am asking the Trust to review the adequacy of the original search and to explain the apparent contradiction between:

1. the Trust’s statement that no relevant A-EQUIP / PMA records are held; and

2. the Trust’s own risk assessment relying on PMA restorative clinical supervision / support as part of its controls.

Please could you add this email to the existing internal review for FOI 9559 and confirm when I can expect to receive the internal review outcome.

Kind regards,
Emma