Complaints to Trust & HOSC

Formal complaints raised regarding the behaviour of the NHS Trust and inadequate scrutiny of their actions by the Health Oversight Scrutiny Committee.

HOSC Complaint

From: Emma's Antenatal - Info <info@emmasantenatal.com>

Subject: Formal Complaint – Handling of Scrutiny Concerning the Suspension of Home Birth Services by Gloucestershire Health Overview & Scrutiny Committee

Date: 2 December 2025 at 09:34:06 GMT

To: complaints@gloucestershire.gov.uk

Cc: democratic.services@gloucestershire.gov.uk, Rob.Ayliffe@gloucestershire.gov.uk, corporatecomplaintsteam@gloucestershire.gov.uk

I am submitting a formal complaint regarding the conduct, handling, and procedural approach of the Gloucestershire Health Overview & Scrutiny Committee (HOSC) in relation to Gloucestershire Hospitals NHS Foundation Trust’s suspension of the home birth service.

My concern is that HOSC has not fulfilled its statutory scrutiny duties, has failed to properly consider relevant evidence, and has provided an inadequate and dismissive response that does not reflect the seriousness of the issues raised.

This letter should be treated as a formal complaint under the Council’s complaints process.

1. Failure to fulfil statutory scrutiny duties

HOSC has a legal responsibility to scrutinise local health services, ensure transparency, and protect the public interest. In this case, the Committee:

• did not meaningfully scrutinise the Trust’s decision to suspend the home birth service

• accepted inconsistent or incomplete statements from the Trust

• failed to challenge or request evidence for claims made about staffing, safety, and skill mix

• did not ensure that the Trust had followed statutory duties relating to consultation, equality, and service change

This represents a failure of governance and a failure to exercise proper scrutiny.

2. Failure to consider the evidence I submitted

I provided a detailed, referenced evidence bundle that included:

• national and international research on home birth safety

• continuity of care evidence

• cost-effectiveness data

• FOI responses demonstrating inconsistencies in the Trust’s narrative

• legal duties under the NHS Act, consultation requirements, and equality legislation

The response from the Chair did not address even a single substantive point raised. There was no indication that the evidence was read, considered, or understood.

3. Inadequate and dismissive response from the HOSC Chair

The reply I received was:

• dismissive in tone

• lacking any engagement with the evidence

• containing factual inaccuracies

• framed in a way that minimised the seriousness of the concerns

• not reflective of the Committee’s duty to protect the public interest

This is not an acceptable standard of scrutiny or public accountability.

4. Consequences of these failings

Because HOSC did not properly scrutinise the suspension:

• women have lost access to a key element of maternity care

• serious questions about the Trust’s processes remain unanswered

• no assessment of alternatives was requested

• the public has lost confidence in the scrutiny process

• elected members were not equipped with the information needed to make informed decisions

This constitutes maladministration.

5. What I am requesting

I am asking the Council to:

1. Review how HOSC handled scrutiny of the home birth suspension.

2. Provide a full response to each of the substantive concerns raised in my evidence.

3. Clarify how HOSC ensures compliance with its legal duties when a health service is withdrawn or significantly altered.

4. Explain how the Committee intends to improve transparency and scrutiny in future, including accurate challenge of public bodies.

5. Confirm what steps will be taken to ensure the Committee can carry out its statutory role effectively.

I would also like this complaint to be escalated to Stage 2 if the Stage 1 response does not adequately address these points.

6. Evidence available

I am happy to provide the evidence bundle submitted to HOSC if required. I have not attached it in full at this stage to avoid overwhelming the initial complaint process.

Yours sincerely,
Emma Gleave

Gloucestershire Maternity Action Group

07922505272

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NHS Trust 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

To: ghn-tr.complaints.team@nhs.net

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