Ed Humpherson to Tony Dent: ONS Economic Statistics Plan, Consumer Prices and UKSA Board and Panels

Dear Tony,

ONS Economic Statistics Plan, Consumer Prices and UKSA Board and Panels

Thank you for your letter dated 4 September 2025 and your follow-up enquiries on 5 September.

You expressed concerns with the status of the Office for National Statistics (ONS)’s CPI and CPIH statistics as accredited official statistics. As mentioned in my letter in March 2025, we are intending to re-assess CPI and CPIH once ONS has incorporated grocery scanner data into its inflation statistics. We recognise that there are competing views about different elements of the calculation of the consumer price indices, and we are continuing to encourage ONS to improve transparency around its approach. Our thinking remains open on this issue, and we plan to discuss this with a range of users, including you and your colleagues at Better Statistics.

You referenced the need for a way for users to communicate their concerns directly to the appropriate advisory committee, particularly the two UKSA consumer prices advisory panels (the Technical and Stakeholder Panels). These advisory panels can consider issues raised by users; if this has not been your experience, please let me know and my team can follow up. Separately, you mentioned that you would like to see the prompt release of minutes for UKSA Board meetings. We have referred this request to the Board Secretariat to see what can be done.

Thank you for your comments on the ONS Plan for Economic Statistics and the additional ONS Survey Improvement and Enhancement Plan. Following the publication of OSR’s 2025 State of the Statistical System report in July, I wrote to the new ONS Director General for the Economic, Social and Environmental Group, James Benford.

While in this letter I reaffirmed that the Plan for Economic Statistics met “OSR’s immediate requirements as a plan of activities to restore confidence, ensure strategic transparency and enhance focus on the quality of data inputs”, I also agreed with your view that this represents a very ambitious programme of work, and that OSR expects further actions from ONS over the longer term to build confidence. OSR has also requested quarterly reporting of progress from ONS against the milestones. So our judgement, as set out in our public statements, remains one of wanting to see how well ONS is able to deliver on these plans.

In your follow-up email, you asked for more information about the users we spoke to for our compliance review on the transformation of CPI and CPIH. These included users from the Bank of England, HM Treasury, the Royal Statistical Society, the Trades Union Congress, the Resolution Foundation, the Northern Ireland Statistics and Research Agency and the University of Southampton.

Finally, you requested any documentation about how the ONS applies hedonic regression in its calculations of inflation measures. This information is not currently located in one place. For details on its use in private rents statistics, for example, see Section 6 of the Price Index of Private Rents Quality & Methodology Information (QMI) document. For the calculation of consumer prices inflation, in our view the best resource is the Consumer Prices Indices Technical Manual.

In our regulatory work, we have set out requirements (for example Requirement 2 in our PIPR Assessment and the recommendations in our recent CPI-CPIH Compliance Review) asking ONS to improve the way it disseminates its information about its data and methods to a range of audiences. This includes setting out end-to-end documentation outlining the complete production process.

Our requirements remain outstanding, and the example of hedonic regression which you have highlighted illustrates that ONS has more to do to address this need. Please let us know of any specific thoughts you have about what ONS could do to better communicate its approach to hedonic regression.

Yours sincerely

Ed Humpherson
Director General for OSR


Related

Tony Dent to Ed Humpherson: ONS Economic Statistics Plan, Consumer Prices and UKSA Board and Panels

Ed Humpherson to Dr James Noyes: SMF report on gambling tax reform

Dear James,

SMF report on gambling tax reform

Thank you for taking the time to meet and for allowing us the opportunity to provide more information about the work of the Office for Statistics Regulation and our approach to investigating concerns raised with us.

As you are aware, we were asked to look at the Social Market Foundation’s (SMF) report on The Duty to Differentiate, specifically the language used when referring to analysis taken from the Gambling-related harms: evidence review published by the Office for Health Improvement and Disparities (OHID).

We are pleased that prior to our meeting, you published a correction to the report that explains the SMF report mistakenly referred to “due to” rather than “associated with” when discussing gambling related harm and that the drafting was not intended to imply a causal relationship. This correction is clear and accessible in line with best practice, and we consider the matter closed.

We welcome your continued commitment to the clear and transparent communication of statistics and data.

Yours sincerely

Ed Humpherson
Director General for OSR

Tony Dent to Ed Humpherson: ONS Economic Statistics Plan, Consumer Prices and UKSA Board and Panels

Dear Ed,

Thank you and Rob for the recent discussion, it was gratifying to hear that the OSR has valued some of our commentary.  However, without wishing to carp in any way, I continue to believe our contribution would have been greater had there been a clearer understanding of the structure and purpose of the various elements of UKSA.  We have frequently commented on how our ‘outsider’ perspective differs from your ‘insider’ view and we believe the difference results from the failure of UKSA to communicate its activities effectively.

There are many examples of the difficulties created by poor communications but, probably, none are more significant than the fact that Better Statistics CIC do not understand how the CPI and the CPIH retain their status as Accredited Official Statistics, given the many errors we and others have exposed.  Moreover we fail to understand how they can be considered to be “statistics for the public good”.

Whilst we recognise that the OSR’s role as the assessor of the efficacy of these measures must be influenced by the two Advisory Panels on Consumer Price Statistics (APCP), we have no explanation as to how the various parties actually inter-relate to achieve a co-ordinated opinion.  In our view this lack of clarity contributes to the confusion evidenced by the public’s inability to recognise UKSA’s opinion of the value and purpose of these measures.  A confusion recently highlighted by the BBC announcer who said that “most households” would be experiencing a higher inflation rate than the July rate published by the ONS.  This dissonance, between personal experience and the ONS measures, lies at the core of the mistrust which many people have with our statistics.  A mistrust that long preceded the controversies of the past year or two, with consequences that UKSA continue to ignore.

Turning to the wider issue of our economic statistics, we note that the web-site announcement of the OSR’s State of the UK Statistical System 2025, includes the assurance that “In our view, the Office for National Statistics (ONS)’s recently published plan for economic statistics provides the right foundations to restore confidence in ONS”,  however we fail to see how that view is supported by the publication.  Have we missed something?  To us, the plan lacks explanation as to how the ambitious series of deadlines for improvements across every area will be achieved, even considering the additional ONS Survey Improvement and Enhancement Plan for Economic Statistics.  Both plans appear to lack the details required to explain how resources will be deployed, with the main plan lacking explanation as to the objectives of, or reasons for, many of the activities.

See for example: “A2.3 Sustainable operation:

We are planning to extend the coverage of our Large Case Unit and our Account Management Units, and so extend their proven impact on data quality and simplify engagement with more businesses. We plan to expand their combined coverage from 150 today to:

  • around 850 business units this year (2025 to 2026)
  • increasing to in the region of 1,800 business units in 2026 to 2027
  • rising to a combined total of around 4,000 business units by the end of 2027 to 2028.

BSC would prefer to see some explanation for these numbers – specifically what benefits are expected from the increased sample sizes?   We would also prefer to see consideration of alternative approaches, such as the use of cluster sampling to reduce Household survey costs and a trial of mix-mode data collection to include alternative methods such as time use surveys.  We consider that the latter would more readily capture the details of those persons seeking to hold down two or three jobs, or others with complex lifestyles.  However, although the OSR is charged with preparing the annual reports on the state of the UK Statistics System, we understand that comments  such as those above are not within your purview.

Meanwhile we welcome the ambition of the ONS for a “Refreshed Citizen Relationship – to improve trust, brand recognition and understanding of the importance of our surveys” and we hope that this will encourage more urgent consideration of the inflation measures as mentioned above.  Also, we hope that the ONS now accept that not all citizens listen to radio 4!  The frequent mentions of ONS activities on the Today Programme had been evidenced by the ONS as sufficient publicity, when BSC had suggested advertising the Covid-19 Infection Survey to improve the response rate from the lamentable 11% of households sampled.

Anyway, to return to our recent meeting.  I am sure you will recall our opinion  that the provision of prompt and informative minutes of the Advisory and Main Board meetings would greatly improve UKSA’s communications.  It being expected that such meetings should be  more robust in considering statistical details, because a statistic is a relatively ephemeral, point in time, estimation that, normally, will be different on another occasion. It is NOT immutable and one would expect the relative advisory boards to be more open in their discussions as to the level of reliability required and the methods used.

The current suppression of any disagreement is actually anathema to a healthy statistical operation, which should be more concerned with discussion of the policy risks associated with unreliable data. Public discussion of the important issues underlying such matters can only be for the public good.  One clear recommendation we would make to improve public trust would be to provide a conduit for users to communicate their concerns directly to the appropriate advisory committee, particularly the two committees advising on inflation measurement.  The SUN platform could be used for this purpose, were it to be more concerned to encourage public participation, instead of controlling it.

I hope you will give these remarks further thought and, possibly, discuss them with your colleagues.  In particular, BSC would appreciate a direct answer as to the accreditation of the CPI and CPIH and, accordingly, we propose to publish this letter in due course.

Finally, we have given further thought to  the proposed seminar “Growing the UK Economy – how can business contribute?“.  That seminar was partly inspired by the fact that the business community was not well represented at the Assembly earlier this year, nor is business much engaged with the Government Statistical System in general.

We had hoped to make a contribution to a ‘refreshed citizen relationship’ with this seminar and we’d like to discuss that with you at your convenience.

With all good wishes,

Tony

On behalf of Better Statistics CIC


Related

Ed Humpherson to Tony Dent: ONS Economic Statistics Plan, Consumer Prices and UKSA Board and Panels

Ed Humpherson to Stephanie Howarth: Response to National Survey for Wales request to temporarily suspend Accredited Official Statistics status 

Dear Stephanie,   

Thank you for your letter requesting a temporary suspension for the accredited official statistics status for outputs based on the 2024-2025 National Survey for Wales data. This request is due to a smaller than expected achieved sample size for the survey in 2024-25 which will impact on the quality of estimates at lower levels.  

Based on your investigations, we agree with your request to suspend the accreditation of the National Survey for Wales statistics. We understand that data derived from the National Survey for Wales are used to inform national well-being indicators in Wales. Therefore, please do consider any potential quality impacts on other statistical outputs that rely on this data, such as the annual Wellbeing of Wales statistics. 

We welcome your plans to publish the release of 2024-2025 results as official statistics in development and your commitment to be transparent in your guidance for users on how the data should be used and interpreted. We also support your future ambition to increase the achieved sample size by moving from a telephone-first to an online-first approach. 

My team will be happy to engage with you about the most appropriate timing for a review of these statistics. This will be with a view to reinstating accreditation once you feel assured that they fully comply with the Code of Practice for Statistics.    

Yours sincerely,  

Ed Humpherson

Ed Humpherson to Professor Jonathan Portes: GDP per Head Estimates

Dear Jonathan,

Thank you for your email dated 15th May 2025 raising concerns about the Gross Domestic Product (GDP) per head figures published that day as part of the first quarterly estimate of GDP statistics for January to March 2025. We have addressed each of your concerns in turn below.

You expressed your view that the national population projections used for the GDP per head calculation were not ONS’s best available projection for the population. We agree that over the last few months, new data released by ONS have shown that international migration has been dropping and as a result, the principal projection used in the national population projections has become a less reliable reflection of short-term projections of the population. Instead, the migration category variant appears to have been providing a more likely short-term scenario of the impact of migration on population numbers.

We note that on 24 June, ONS published updated sub-national population projections, which advised the use of the migration category variant in place of the principal projection, as this is a better reflection of short-term population change. This recommendation was also accompanied by a blog explaining the issue for non-expert users. We welcome this response from ONS, and the migration category variant was subsequently used for the GDP estimates released on 30 June.

Following this change, you were concerned that users were not made aware that the migration variant category was being used. We have reviewed the ONS communications linked above as well as the GDP quarterly National Accounts: January to March 2025 publication released on 30 June, and the National accounts revision policy. Overall, our view is that the change to the migration variant category has been communicated to users upon its introduction, including updates to published material and clarity on what population data have been used in those calculations. We recognise that in future cases, and where possible, ONS could consider how the change is communicated in advance of the publication and how the impact of the change is explained to users. We have shared these views with ONS.

You also raised a concern about the use of annual population projections as the denominator for the GDP per head calculations, which use quarterly and seasonally adjusted GDP data as the numerator. We agree that this is a limitation of the calculation. We understand that ONS is considering the best way to reflect the latest available demographic statistics in the production of economic statistics such as GDP per head and that one option being considered is a quarterly time-series informed by quarterly population data rather than a linear interpolation, as is currently used. If implemented, this would allow the GDP per head calculations to be based on quarterly population projections. We understand that this work is in its early stages and encourage ONS to keep users updated.

Finally, you questioned whether ‘estimate’ is an appropriate descriptor for GDP per head, and you noted your preference for the term ‘implied’. We appreciate your view and have taken it into consideration. We agree that ‘estimate’ is not the most technically accurate term; however, unfortunately, we have been unable to identify an alternative that is technically correct whilst still understandable and interpretable by the non-expert user. We have passed your views on this issue to ONS so that that it can consider how it communicates and explains the concept of GDP per head in its releases.

Thank you for getting in touch with us.

Yours sincerely

Ed Humpherson
Director General for OSR

Ed Humpherson to Chris Roebuck: NHS England Accident and Emergency statistics: Confirmation of accredited official statistics status

Dear Chris

We have independently reviewed the actions that NHS England has taken to address the six requirements outlined in our assessment report. On behalf of the Board of the UK Statistics Authority, I am pleased to confirm that they comply with the standards of Trustworthiness, Quality and Value in the Code of Practice for Statistics and should be labelled as accredited official statistics. The detail supporting our judgement is included in the annex to this letter.

The performance of the National Health Service in England is a hugely topical issue, often covered in public and political discourse. Individuals and organisations want to hold the UK Government to account against its commitments, understand what level of service can be expected in local areas and understand how performance compares against other areas and countries.

We welcome the actions you have taken to improve the value of these statistics for users. The publication of a development plan for the statistics and a dedicated data quality page increases transparency, supports users to understand and use the statistics appropriately, and allows users to feed into development plans. We also welcome the hard work the statistics team has put into expanding its user engagement and responding to user requests for more-granular data. These activities demonstrate your willingness to listen to a range of different users and address their needs. Your ongoing development work, for example exploring the feasibility of publishing site-level data, demonstrates your commitment to meeting user needs and upholding the standards of the Code of Practice for Statistics. We look forward to hearing about the outcome from this work.

I would like to thank your team for its open and constructive engagement throughout our assessment and for your ongoing commitment to improving these statistics.

Yours sincerely

Ed Humpherson
Director General for OSR

Related links:

Mark Svenson and Chris Roebuck to Ed Humpherson: Request for assessment of A&E outputs – Office for Statistics Regulation 

Ed Humpherson to Mark Svenson and Chris Roebuck: Request for assessment of NHS England A&E statistics – Office for Statistics Regulation 

Ed Humpherson to Mark Svenson and Chris Roebuck: Assessment of NHS England’s A&E statistics – Office for Statistics Regulation 

Accident and Emergency Statistics produced by NHS England: Assessment of compliance with the Code of Practice for Statistics – Office for Statistics Regulation 

Review of actions taken in response to Assessment Report 382, Accident and Emergency Statistics produced by NHS England

Requirement 1: NHS England should review and reduce its pre-release access lists, bearing in mind the principles of good pre-release practice, to support the principle of equality of access and reduce the risk of data leaks. As part of meeting this requirement, NHSE should share its justification for each requirement with OSR.

Actions taken by NHS England: The NHS England team reviews the pre-release access list on a regular basis and reduces the list when possible. The team provided OSR with justifications for all those included on the list. The statistics teams and Heads of Profession for both NHS England and the Department for Health and Social Care (DHSC) work closely with their respective communications teams and private offices to ensure that colleagues in these teams understand their obligations under the Code of Practice and pre-release access. Clear wording is included in the title and content of emails sharing pre-release materials to ensure appropriate use.

OSR’s evaluation of evidence: We consider this requirement to be met. While the overall length of the pre-release access list has not been reduced, we consider the justification provided for those included on the list to be valid. We are satisfied that both NHS England and DHSC have sufficient mitigations in place to manage the risks associated with a long pre-release access list.

 

Requirement 2: NHS England should publish a development plan for its A&E statistics to enhance transparency and allow users to input to developments. It should share this plan both with its known users and more generally on its website, to ensure it reaches as wide a range of individuals and organisations as possible.

Actions taken by NHS England: NHS England has published a development page for its A&E statistics. This page invites feedback from users on recent changes to the statistics and shares plans with users regarding the ongoing development of the statistics. The page also includes information about how NHS England carries out engagement about the statistics with internal and external users.

OSR’s evaluation of evidence: We consider this requirement to be met. The publication of a page which details ongoing and future developments, and NHS England’s user engagement activities, improves transparency. Importantly, it also provides opportunities for users to feed into this work.

 

Requirement 3: NHS England should expand and improve its published information about quality and methods to help users understand the strengths and limitations of the statistics and support appropriate use of them. This should include explanations about the level of uncertainty associated with the statistics, including confidence in the accuracy of data submissions, and what this means for their use, as well as the quality assurance processes carried out. It would also be helpful to provide a summary of the data journey, from data submission to publication.

Actions taken by NHS England: NHS England has published a data quality page for its A&E statistics. This page provides summary information on data completeness and quality assurance for both data sources used to produce the statistics. It includes several links to more-technical information about data quality as well as a flow chart explaining the flow of data from trusts to final publication.

OSR’s evaluation of evidence: We consider this requirement to be met. The introduction of a dedicated data quality page is an important addition for users of the statistics. During the assessment, we found that published information on quality and methods did not consistently provide enough detail to fully reassure users about the quality of the statistics. We also found that users had to work quite hard to find relevant quality information, as it was spread across several parts of the website. The new page brings together key information about the data sources and their quality. It provides users with guidance on the implications of any quality issues on the use of the statistics and allows users who require more detail to easily access more-technical documentation.

 

Requirement 4: NHS England should regularly and proactively engage with a wider range of users to understand their needs and implement improvements to the statistics which enhance their public value. It might be helpful to NHS England to publish a short user engagement plan setting out its intentions in relation to meeting this requirement.

Action taken by NHS England: NHS England has proactively contacted several organisations which use its A&E statistics, such as professional groups, health think tanks and research organisations, the House of Commons Library and media outlets, with a view to seeking their feedback.  On its new development page, NHS England has published information about its user engagement activities and plans.

OSR’s evaluation of evidence: We consider this requirement to be met. We are pleased to see NHS England expand its user engagement activities beyond its core stakeholders. This will broaden the team’s understanding of the range of users of the statistics and their needs.

 

Requirement 5: NHS England should combine the 12-hour waits information with other monthly statistics about A&E and improve signposting between outputs on this topic to improve the overall accessibility of A&E statistics and insights that they provide.

Actions taken by NHS England: NHS England has improved signposting between its monthly A&E statistics and information about 12-hour waits. The statistics team considered merging these two outputs, but given the statistics come from two different data sources, the decision was made to keep the analyses separate.

OSR’s evaluation of evidence: We consider this requirement to be met. While NHS England has not combined the 12-hour waits information with its other monthly statistics, we consider that the reasoning for this is valid and that the improved signposting between the two outputs is sufficient to address the requirement.

 

Requirement 6: Building on its current progress in responding to users’ requirements, NHS England should explore the feasibility of publishing more-granular information in its monthly A&E publication to enhance the insights provided by the statistics. Based on user feedback, the priority for this work should be providing site-level breakdowns.

Actions taken by NHS England: In response to user requests, NHS has published more-granular breakdowns of its A&E statistics, including breakdowns by age, gender, ethnicity, chief complaint and frailty. NHS England has used the Emergency Care Services Dataset (ECDS), which, at record level, enables the production of summaries for specific care areas and patient characteristics.

On its new development page, NHS England welcomes user feedback on other areas of interest from ECDS data. On this page, NHS England also explains that it is currently exploring whether publishing site-level data would be beneficial for users and in the best interest of patients and their outcomes.

OSR’s evaluation of evidence: We consider this requirement to be met. We are pleased to see NHS England responding to user requests by publishing more-granular breakdowns of the statistics. This was a key user need we identified during our assessment. Although NHS England has not yet been able to include site-level breakdowns in the statistics, it has publicly committed to exploring this addition on its new development page. The team has also agreed to keep users updated on the outcome of this work.

Jessie Evans to Ed Humpherson: Request to remove accreditation

Dear Ed,

I am writing to formally request that the official statistics accreditation be removed from our Digital Sector Economic Estimates: Employment series. If this request is accepted, we intend to publish releases in the series as official statistics in development until further review.

Following the suspension of the accreditation of Office for National Statistics (ONS) labour market statistics based on the Labour Force Survey (LFS) and Annual Population Survey (APS), we have reviewed the accreditation of our APS based Digital Sector Economic Estimates: Employment series.

The Digital Sector Economic Estimates: Employment series is currently classed as accredited official statistics and is used to provide an estimate of the number of filled jobs in the Digital Sector. These employment estimates are produced by restructuring and aggregating APS data relating to Digital Sector SIC codes. Employment data are then presented through various demographic and industrial breakdowns.

ONS has reported concerns with the quality of estimates for smaller segments of the APS population, which the Digital Sector Economic Estimates: Employment series depends upon. Reduced APS coverage of Digital Sector SIC codes reduces the reliability of our employment estimates. Furthermore, the increased volatility of APS estimates due to low sample sizes affects the validity of any observed changes in Digital Sector employment estimates. Our approach in moving the Digital Sector Economic Estimates: Employment series to official statistics in development would be in line with ONS’s decision to consider their APS based labour market statistics as official statistics in development until further review.

In addition to classifying Digital Sector Economic Estimates: Employment estimates as official statistics in development, we intend to reduce the demographic and industrial breakdowns we publish to reduce low sample values.

We will continue to ensure we are transparent with users on how reliable our estimates are. We will continue to provide appropriate advice and caveats in our publications for users of our data and will apply suppression where appropriate.

Yours sincerely,

Jessie Evans

Chief Statistician, DSIT

Related links: Ed Humpherson to Jessie Evans: Request to remove accreditation – Office for Statistics Regulation

Ed Humpherson to Jessie Evans: Request to remove accreditation

Dear Jessie

Thank you for your letter setting out findings from your review of Digital Sector Economic Estimates: Employment statistics, following the suspension of the accredited official statistics status for labour market statistics from ONS’s Labour Force Survey (LFS), on which the Annual Population Survey (APS) estimates are based. As you explain, your employment statistics are produced by restructuring and aggregating APS data relating to Digital Sector Standard Industrial Classification (SIC) codes.

Based on the quality concerns you outline, I agree to your request to temporarily remove the accredited official statistics status from the following output:

This approach, along with the advice and caveats you provide in your publications, will ensure clarity for users about the quality issues you have found.

Our Economy, Business and Trade team will continue to engage with your team on this matter.

Yours sincerely

Ed Humpherson
Director General for OSR

Related links: Jessie Evans to Ed Humpherson: Request to remove accreditation – Office for Statistics Regulation

Ed Humpherson to Lord Moylan: Abortion Statistics for England and Wales (18 June 2025)

Dear Lord Moylan

Thank you for your letter of 6 May regarding abortion statistics for England and Wales produced by the Department for Health and Social Care (DHSC).

I appreciate your concern regarding the timeline for our compliance check. As the regulator for official statistics, our remit concerns published statistics. We do not regulate administrative systems from which data for some official statistics are collected. As such, any regulatory work that we conduct will be focused on the published statistics. Because of this, we have judged that the most appropriate time for us to undertake a compliance check is after the current development work on the data submission process has concluded but before the subsequent annual release – so in the first quarter of 2026/27. This will ensure that we are able to support the team in the lead up to the publication and provide advice on areas for improvement.

I have also considered the additional points made in your letter of 6 May. You are correct to point out that complications dealt with by a GP or through 111 are unlikely to be captured by abortion forms (though it is possible that they can be). This is one of the limitations of the data source and is explained by DHSC in its 2023 comparison analysis. However, as I set out in my previous correspondence, using abortion forms, rather than hospital data, as the data source for complications does have several strengths. These strengths include that the data cover both England and Wales, and, crucially, provide a denominator for calculating complication rates.

You also questioned the relevance of user demand for the statistics. Whilst the collection of the data is covered by the relevant legislation, the Code of Practice for Statistics requires producers to understand their users and address user views, where practicable, in relation to the publishing of statistics. We understand from DHSC that it has not received strong user demand for additional analysis of complications based on hospital data. Given this and the resource constraints facing DHSC, as I said in my previous letter, we understand DHSC’s decision not to routinely publish this information.

I hope this letter addresses your concerns. I would be happy to meet with you for a discussion if it would be beneficial.

Yours sincerely

Ed Humpherson
Director General for OSR

Related Links:

Lord Moylan to Ed Humpherson: Abortion Statistics for England and Wales (20 January 2025)

Ed Humpherson to Lord Moylan: Abortion Statistics for England and Wales (20 February 2025)

Lord Moylan to Ed Humpherson: Abortion Statistics for England and Wales (6 May 2025)

Lord Moylan to Ed Humpherson: Abortion Statistics for England and Wales (6 May 2025)

Dear Mr Humpherson,  

I apologise for not replying before to your letter of 20th February send in response to mine about statistics on complications arising from abortion. I am glad that you have agreed to undertake a compliance check of the statistics on abortion complications published by DHSC to ensure they meet the standards in the Code of Practice for Statistics. I am only disappointed that the check is to be delayed until the first quarter of 2026/7.

One of the reasons for the delay, you say, is to allow time for DHSC to work with digital experts and system providers “to improve the design of the Abortion Notification System”. I find this rather alarming, as it seems to me to put the cart before the horse. Given the manifest inadequacy of the Abortion Notification System to capture more that a small number of complications, would it not be better for the compliance check to be undertaken first so that the inadequacies, and remedies for them, could be identified and this analysis then be used as a basis for improving the design of the ANS? I should be grateful to know what your reflections on this might be.

Perhaps I could comment on a few other points on your letter, but as background may I just be clear these are “national statistics” which are required to be collected under statute (Abortion Regulations 1991, regulation 4 and schedule 2, which specifies the complications to be reported). It is not therefore wholly relevant whether there has been “user demand” for the more comprehensive data set produced by the Office for Health Improvements and Disparities in November 2023 and in any event, it is not clear who the relevant “user” should be, since the availability of reliable statistics on complications goes to the question of informed patient consent, not merely to the interest shown by clinicians.

There are always of course certain advantages in maintaining a statistical series over time and you state that this is also true in the case of ANS data as currently recorded. But there is no suggestion, certainly not from me, that the collection of ANS returns on complications should be abandoned. Information on complications drawn from ANS data is an indispensable part of the picture, but one of dwindling relevance given the changes in the abortion clinical landscape. Having more robust statistics relevant to the real world would not mean a rupture in the ANS data series. And in any case, ANS data over a much wider field that simply complications. Whilst insufficient for the reporting of complications, the ANS is necessary for those other data.

You refer to the resource constraints faced by analytical teams at DHSC and I can appreciate that the compilation for the first time of relevant Hospital Episode Statistics by OHID will have been somewhat onerous. But each of the complications arising from abortion in a hospital setting is assigned an ICD-10 code and a new system would make routine the central reporting of these codes and the number of incidents pertaining to each. (The ICD019 codes are set out in the Annex to the OHID report.) Indeed this seems to me to illustrate the compelling reasons for you to carry out your compliance check first and then allow the DHSC to spend resources digitalising their collection system once it is clear what data you are looking to collect and whether they should include the relevant ICD-10 codes recorded by hospitals.

Finally, you say that the ANS data capture complications not requiring hospitalisation. I would make the point rather differently. As I said in my earlier letter to you, even with the huge enhancement in robustness achieved by the OHID, there is still a lacuna in regard to complications dealt with by a GP (or for that matter resolved with telephone advice from 111). I do not have a solution to suggest for making good this deficiency except to say that I suspect the numbers are small and that in any case, a GP or 111, presented with the symptoms of the principal recordable complications (haemorrhage, uterine perforation, sepsis) would in any event refer the patient to A&E and thus the case would be captured in the Hospital Episode Statistics.

As you can see, I am concerned that, by deferring the compliance check until after the developments the DHSC envisage are carried out, opportunities will be lost and excuses created for further deferring the improvement in statistics for which the OHID has blazed a path. I should be keen to hear your considered view.

I should be happy to meet if you felt that would be useful.

Yours sincerely,

Moylan

Related Links:

Lord Moylan to Ed Humpherson: Abortion Statistics for England and Wales (20 January 2025)

Ed Humpherson to Lord Moylan: Abortion Statistics for England and Wales (20 February 2025)

Ed Humpherson to Lord Moylan: Abortion Statistics for England and Wales (18 June 2025)