Emails to Gloucestershire Maternity Decision-Makers and Commissioners – 9 November 2025
These three emails bring together key policy, legislation, and proven models of care
— showing clearly that the Trust has a duty to explore these options,
and that commissioners have a responsibility to intervene when those duties are not being met.
Other NHS Trusts have already taken similar steps, demonstrating that collaboration with independent midwives and continuity-based models is both possible and effective.
Dear Mr Devlin,
Congratulations on your appointment as Chief Executive of NHS Gloucestershire ICB and the wider cluster.
I am writing regarding the ongoing suspension of Gloucestershire’s home-birth service. Despite several attempts to engage with the current ICB leadership, there has been no substantive response.
The withdrawal of home-birth support has left women—particularly in the Forest of Dean—without any local maternity provision and with no clarity on when services will resume.
Families are now forced either to travel long distances while in labour or to give birth at home without professional support. Both outcomes are unsafe and inconsistent with the NHS’s stated commitment to equity, continuity, and community-based care.
Under the Health and Care Act 2022 and the NHS Act 2006, the ICB has a statutory duty to commission comprehensive and equitable maternity services and to intervene where provider decisions create unsafe or inequitable gaps in care.
Home birth is not a luxury; it is a core, evidence-based component of safe maternity care.
NICE Guideline CG190 and Better Births (2016) confirm that planned home birth for low-risk women is as safe as hospital birth, with fewer interventions, higher satisfaction, and lower cost to the NHS.
Policy and governance obligations
NHS England’s Policy on Working in Partnership with People and Communities (July 2022) requires all ICBs to “work with people and communities as partners in decision-making at every level of health and care.”
The recent RCM publication Guidance for Transforming the Maternity Workforce (Section 1, Nov 2024) also emphasises the importance of role development, collaboration, and flexible partnerships to maintain safe staffing and continuity.
Furthermore, the Parliamentary and Health Service Ombudsman’s investigation into Queen Elizabeth Hospital King’s Lynn NHS Trust (2012) found maladministration where maternity services failed to plan for known risks and did not explore reasonable alternatives when withdrawing provision.
Together, these documents make it clear that ICBs must demonstrate imaginative, proportionate solutions when services are withdrawn.
Introducing Zest Midwives – a compliant, ready-to-implement solution
Recently, the Head of Midwifery in Gloucestershire stated that the Trust cannot contract Independent Midwives because “there is no mechanism for doing so.”
In fact, such mechanisms do already exist.
Zest Midwives is a national organisation that creates safe contractual and indemnity frameworks between NHS Trusts and Independent Midwives, enabling rapid, compliant deployment when services are under strain.
Zest has a proven track record of success across multiple NHS Trusts and Health Boards. Their model fulfils every requirement of the policies cited above—governance, insurance, oversight, and community partnership—and can restore home-birth provision safely and quickly.
Contracting Independent Midwives through Zest would:
Provide immediate cover for booked home births and prevent unassisted births.
Reduce pressure on overstretched hospital staff.
Enable experienced practitioners to mentor and re-skill NHS community midwives.
Rebuild public confidence and demonstrate the ICB’s commitment to partnership-based reform.
Request
I would be grateful if you could confirm that the ICB will:
Review the current suspension of home-birth services and the commissioning implications.
Meet with Zest Midwives as a matter of urgency to explore contracting options.
Provide a written update outlining contingency plans and timelines for restoring equitable home-birth provision.
I am copying xxx from Zest Midwives into this email, as she would be happy to provide further detail or meet with your maternity commissioning leads to discuss implementation.
Thank you for your time and for considering a solution that upholds both safety and women’s rights while supporting the workforce.
Yours sincerely,
Emma Gleave
Emma’s Antenatal / Wildlings Ed CIC
www.emmasantenatal.com
Dear xxxx,
I am writing regarding the ongoing suspension of Gloucestershire’s home-birth service and the possible next steps for restoring safe community provision.
We have recently been informed that Lisa may not currently be in post, and I wanted to clarify whether that is the case so that correspondence and updates can be directed appropriately.
If leadership responsibility for maternity services has been temporarily delegated, I would be grateful if you could confirm who is now the acting or interim Director of Midwifery.
In the meantime, I wanted to ensure that both of you are aware that I have written to Shane Devlin, Chief Executive of NHS Gloucestershire ICB, introducing Zest Midwives, who specialise in creating compliant contractual pathways between NHS Trusts and Independent Midwives.
As you will know, Independent Midwives are fully NMC-registered and insured, and Zest have successfully supported NHS Trusts and Health Boards across the UK to maintain safe home-birth provision during staffing pressures.
Their work aligns with the NHS England Policy on Working in Partnership with People and Communities (2022) and the RCM’s Transforming the Maternity Workforce (2024) guidance, both of which emphasise flexibility, collaboration, and continuity of care.
Partnering with Zest Midwives could provide immediate cover for booked home births, reduce pressure on hospital staff, and help re-skill community midwives — while demonstrating proactive leadership and commitment to equitable service delivery.
If it would be helpful, I can arrange a short joint call with Tracy from Zest Midwives to discuss how this model has been implemented successfully elsewhere.
Thank you for your continued commitment to the women and families of Gloucestershire during this challenging time. I look forward to hearing who is best placed to progress this conversation.
Kind regards,
Emma Gleave
Emma’s Antenatal / Wildlings Ed CIC
www.EmmasAntenatal.com
Dear xxx,
I’m writing in response to your previous correspondence, regarding the suspension of Gloucestershire’s home-birth service.
I understand from my colleague that you believe there is currently no process or mechanism within the Trust to contract Independent Midwives.
I wanted to follow up on that point, as there are established frameworks being used successfully by other NHS Trusts across the UK.
I would like to introduce Zest Midwives, who specialise in supporting NHS organisations to establish contractual, indemnified partnerships with Independent Midwives.
Their work enables local maternity systems to maintain safe, equitable services when home-birth teams are under pressure — without breaching NHS governance, insurance, or employment frameworks.
Zest are already working with several NHS Trusts and Health Boards across the country who have used this model effectively to maintain home-birth provision and re-skill their community midwives.
I believe this represents a practical, safe, and compliant solution that Gloucestershire could adopt immediately.
Under the Health and Care Act 2022 and NHS Act 2006, the Trust and the ICB have a duty to ensure comprehensive and equitable maternity services. National guidance, including NICE Guideline CG190 and Better Births (2016), identifies home birth as a safe and evidence-based option for low-risk women.
Under the NHS England Policy on Working in Partnership with People and Communities (2022) and the RCM’s Transforming the Maternity Workforce (2024) both require Trusts to act collaboratively, flexibly, and creatively to maintain safety, choice, and community-based care.
I would also draw your attention to the Parliamentary and Health Service Ombudsman’s findings (2012) in relation to Queen Elizabeth Hospital King’s Lynn NHS Trust, where maternity services were found guilty of maladministration after failing to plan adequately for known risks and not exploring reasonable alternatives when withdrawing provision.
The situation in Gloucestershire bears significant similarity, and it is important that the same procedural standards are upheld here.
Given this, I would strongly encourage the Trust to revisit this decision jointly with the ICB, who hold commissioning responsibility for maternity care and have the authority to commission interim or alternative services where gaps occur.
I am copying in Tracy from Zest Midwives, who would be pleased to provide more information or meet with your team to outline how the process works in other areas.
This partnership would:
Provide immediate cover for booked home births and prevent unassisted births.
Relieve pressure on hospital midwives.
Support skill-sharing and mentoring within the community midwifery workforce.
I hope this may open up a more constructive conversation about practical ways forward that ensure women are not left without safe and supported options for birth.
Kind regards,
Emma Gleave
Emma’s Antenatal / Wildlings Ed CIC
www.emmasantenatal.com