Gloucestershire NHS Trust Complaint Response
The Trust’s own documents show that homebirth suspension arose from internal service failure: inadequate senior leadership, lack of consultant midwife oversight, limited training, staff fear, poor guidance, lack of recent experience, and burnout.
Rather than bringing in experienced external support, such as independent midwives or neighbouring-provider mutual aid, the Trust removed women’s access to planned home birth.
The complaint response now claims those alternatives were considered, but the disclosed risk assessment does not evidence a proper options appraisal.
The key paper relied on — the Confidential Trust Board report of 10 February 2026 — has not been disclosed.
The Trusts FOI response also confirms there were no AEQUIP/PMA records, despite staff wellbeing and safety culture being central to the Trust’s justification.
This raises serious concerns about retrospective governance, inadequate consultation, poor transparency, and failure to protect lawful maternity choice.
Our next step is of course to escalate this matter to the parliamentary ombudsman.
Original Complaint
From: Emma's Antenatal - Info <info@emmasantenatal.com>
Subject: Formal Complaint – Suspension of Home Birth Service and Procedural Failings by Gloucestershire Hospitals NHS Foundation Trust
Date: 1 December 2025 at 19:02:31 GMT
Dear Complaints Team,
I am submitting a formal complaint regarding Gloucestershire Hospitals NHS Foundation Trust’s decision to suspend the county’s home birth service and the way this decision has been handled and communicated. I am concerned that the Trust has failed to meet its statutory duties, procedural obligations, and responsibilities to women and families in Gloucestershire.
My concerns fall into the following areas:
1. Failure to follow legal and constitutional duties
The suspension appears to have taken place without the Trust fulfilling its obligations under:
The NHS Act 2006
The NHS Constitution
Equality and human rights duties
Principles of good public administration
Requirements for consultation or engagement when withdrawing or materially altering a service
There is no evidence of a formal decision-making process consistent with these duties, nor of appropriate governance, risk assessment, or public consultation.
2. Inadequate and inconsistent justification for suspending the service
The Trust has publicly stated that the suspension is due to “safety”, “skill mix”, “increasing complexity" issues, yet simultaneously reports the highest midwife staffing levels seen in Gloucestershire.
These statements do not align.
No clear evidence has been provided to justify the suspension, nor to demonstrate how the Trust assessed risk, explored alternatives, or mitigated the consequences for women.
3. Failure to consider reasonable and available alternatives
There appears to have been no meaningful assessment of options such as:
Contracting Independent Midwives
Short-term continuity teams
Temporary community staffing models used successfully in other Trusts
The decision to suspend the service without exploring solutions that would maintain safe community provision is a serious procedural failing.
4. Lack of transparency and failure to provide accurate or complete information
Communication from the Trust has been inconsistent, unclear, and in some cases factually incorrect. Significant information has been withheld from the public and from the Health Overview & Scrutiny Committee, undermining informed scrutiny and eroding public trust.
5. Impact on women and families
The suspension removes a key element of safe, evidence-based maternity care. It places additional and avoidable risk on women who now must travel further, birth in unfamiliar environments, or face delayed care. This has not been acknowledged or mitigated.
6. Failure of senior leadership to engage with women and local representatives
The Trust’s Chief Executive has publicly stated that he “listens to women,” and has claimed to be working with the MNVP in relation to this suspension. However, the current temporary MNVP representative has confirmed that she cannot represent the voices of women in Gloucestershire in this context. Despite significant concerns raised by local women, midwives, and birth workers — including petitions, direct correspondence, and evidence submissions — the Trust’s Chief Executive has not acknowledged or responded to these concerns. This lack of engagement contradicts the Trust’s stated commitment to listening to women and undermines public confidence in the decision-making process.
Failure to engage with women’s collective concerns
Alongside my individual correspondence, an open letter has been submitted representing approximately 180 women, parents and local residents who are directly affected by this service suspension. This letter outlines shared concerns about safety, access, and the legality of withdrawing a community maternity service without consultation. The Trust has not acknowledged this collective representation nor explained how women’s views have been incorporated into decision-making.A copy of the open letter and signatures can be provided on request.
What I am requesting
I am asking the Trust to provide:
A full explanation of the process by which the home birth suspension decision was taken, including minutes, risk assessments, workforce analyses, and governance documents.
Evidence of how statutory duties, equality duties, and consultation requirements were met.
Clarification of the evidence relied upon to justify the suspension, particularly in relation to safety and staffing.
An explanation of what alternatives were assessed, why they were rejected, and whether contracting Independent Midwives was considered.
A clear outline of the Trust’s plan for reinstating community-based midwife-led care and maintaining safe choice for women.
A full response to the procedural issues raised above.
I would like this complaint to be handled under the Trust’s formal complaints process. If elements of this complaint fall under the responsibility of another organisation (e.g., the ICB), please confirm that you will forward the relevant sections to them, in line with NHS complaints regulations.
I am happy to provide additional evidence if required, including the referenced bundle submitted to HOSC.
Please confirm receipt of this complaint and advise when I can expect a full response.
Yours sincerely,
Emma Gleave