Health and Care Bill

Health and Care Bill: Ensuring Integrated Commissioning of Women’s Reproductive Health in England

Written evidence submitted to the Public Bill Committee  on behalf of the Faculty of Sexual and Reproductive Healthcare  (FSRH) and the Royal College of Obstetricians 

and Gynaecologists  (RCOG ) (HCB66)

What is the opportunity in SRH?

· We believe that Integrated Care Systems (ICSs) have the potential to deliver an integrated model of SRH commissioning so women are able to have all their reproductive health needs met via single point of care.

· Women should have choice over the SRH that they need and want. This means ensuring easy access to all methods of contraception, and the necessary SRH support pre- and post-pregnancy, through the menopause and beyond – as outlined in the FSRH’s Vision.

· To make this a reality, SRH should be more broadly integrated into women’s healthcare pathways in the NHS, focusing on the needs of the individual throughout their life-course. For example, women’s reproductive needs should be considered as part of post-partum healthcare with the full range of contraceptive options offered within seven days of delivery (as per NICE guidelines).

· The Health and Care Bill, alongside the Sexual and Reproductive Health Strategy and the Women’s Health Strategy, provide an opportunity for greater integration and collaboration within the healthcare system.

· Ensuring access to high-quality SRH is highly cost-saving for the NHS and wider society. Public Health England (PHE) recently estimated that for every £1 spent on LARC in a primary care setting, the public sector saves £48, and for every £1 spent on contraception in maternity settings, a return of £324.

What are we calling for from the Health and Care Bill?

1. Holistic commissioning and integration of SRH:

o We call on the Government to work effectively across system level (ICS) and national level (NHSE) to integrate the women’s health services currently commissioned by CCGs with those commissioned by NHSE and LAs – addressing gaps in the reproductive care pathway.

o We call on system leaders to work in partnership with representatives from the SRH community at a national and local level to understand the commissioning needs in their area, in line with NHSE’s interim guidance with regards to development of local plans to transition CCG functions to Integrated Care Boards (ICBs).

o The legal duty for NHS organisations and LAs to collaborate should mandate collaborative commissioning and properly enshrine accountability to address the fragmented commissioning landscape in SRH.

2. Greater oversight and accountability for women’s health at ICS level:

Whilst acknowledging that local flexibility is key based on the geographical reach of each ICB and ICP, we would support the following:

o Representation of a women’s health lead on each ICB to implement holistic women’s reproductive healthcare services at a regional level.

o Representation of a women’s SRH lead within Integrated Care Partnerships (ICPs) to ensure leadership at place level . This is in line with NHSE’s interim guidance which states that membership of IC Ps should be representative of the different population groups it serves .

3. Clinical leadership at a national level – appointment of a National Clinical Director (NCD) for women’s reproductive health or a National Specialty Adviser in Community Sexual and Reproductive Healthcare (CSRH), or similar, to ensure national accountability for ensuring access and improved outcomes in SRH. Alternatively, we would welcome an extended remit for the National Clinical Director for Maternity to include women’s SRH.

4. Ensuring targeted approaches to engage with vulnerable and marginalised groups on SRH – we support calls for IC B s to develop plans which include the need to identify and monitor inequalities between different groups of people within the population of its area. We also call for the effect of inequalities in SRH to be examined, with the need for meaningful engage ment with impacted groups to be incorporated into plans .

For further information please contact:

Catrin Hughes, External Affairs and APPG Manager



Zoe Russell, Public Affairs Manager


Email: zrussell@RCOG.ORG.UK


Health Foundation. Taking our health for granted, 2018.

2 Advisory Group on Contraception. At tipping point, 2018.

3 Wellings, K. 2013. The prevalence of unplanned pregnancy and associated factors in Britain: findings from the third National Survey of Sexual Attitudes and Lifestyles (Natsal-3). Lancet 382(9907): 1807–1816

4 Public Health England. ‘Extending Public Health England’s contraception return on investment tool’, 2021.

About FSRH

The Faculty of Sexual and Reproductive Healthcare (FSRH) is the largest UK multi-disciplinary professional membership organisation working at the heart of sexual and reproductive health (SRH), supporting healthcare professionals to deliver high quality care. It works with its 15,000 members, to shape sexual reproductive health for all. It produces evidence-based clinical guidance, standards, training, qualifications and research into SRH. It also delivers conferences and publishes the journal BMJ Sexual & Reproductive Health in partnership with the BMJ. For more information please visit:

About RCOG

The Royal College of Obstetricians and Gynaecologists (RCOG) is a medical charity that champions the provision of high quality women’s healthcare in the UK and beyond. It is dedicated to encouraging the study and advancing the science and practice of obstetrics and gynaecology. It does this through postgraduate medical education and training and the publication of clinical guidelines and reports on aspects of the specialty and service provision. For more information, visit:

September 2021


Prepared 16th September 2021