In 2022, official reporting of abortion complications by the Office for Health Improvement and Disparities (OHID) shows just 300 cases across England and Wales.[i] For the year 2022-23, official data from NHS England show 11,256 women diagnosed with abortion complications at an NHS hospital.[ii] The NHS data are known to the OHID, as evidenced in its November 2023 report which compares these two data sources, Abortion Notification System (ANS) and Hospital Episode Statistics (HES),[iii] and yet government officials refuse to make any change to official annual reporting.[iv] The NHS England data are easily accessible by any interested person and the above 11,256 can be retrieved online from NHS Digital in a matter of minutes. No prolonged data compilation, cleaning, and analysis; no need for a Freedom of Information request.
Comparing Reported Complications
Over the last four years, Percuity has published a number of reports outlining the significant gaps in the reporting of abortion complications.[v] Some of these relied upon long periods of time taken to gather data from Freedom of Information requests,[vi] but this approach is so much simpler; the data in this table and graph were gathered online and complied in just a few hours.
| Year | ANS | HES |
| 2017 | 303 | 9,593 |
| 2018 | 336 | 9,883 |
| 2019 | 337 | 10,228 |
| 2020 | 247 | 8,618 |
| 2021 | 299 | 10,078 |
| 2022 | 300 | 11,256 |
| 2023 | 12,287 |
In the table above, ANS data are for England and Wales in the noted calendar year (January to December); HES data are for England in each period of twelve months from e.g., April 2017 to March 2018.

Materials and Methods
Each year, NHS Digital publishes accredited official statistics related to ‘Hospital Admitted Patient Care Activity’.[vii] The latest set of data are for the period 01 April 2023 to 31 March 2024.[viii] Under ‘Resources’, there is an Excel file named ‘Hospital Admitted Patient Care Activity, 2023-24: Diagnosis’.[ix]
The data used can be found on the Excel tab named ‘All Diagnoses 4 Character’, in rows 5414 to 5422.

In our analysis we chose to include data for the ICD-10 code O044.
In its comparison report, the OHID states that it considered but did not use the ICD-10 code ‘O044: medical abortion – incomplete, without complication’. This key issue was raised during the second reading of Lord Moylan’s Private Member’s Bill on 13 December, by Baroness Foster of Aghadrumsee.[x]
When compiling results from our recent FOI investigation,[xi] we discussed this with a few A&E and OB/GYN professionals, each of whom confirmed that women diagnosed with O044 would have been assessed by ultrasound and found to be suffering from an incomplete abortion and subsequently treated for removal of retained products of conception. Her symptoms at the time of presentation may not have indicated an infection or troublesome bleeding, but the ultrasound confirmed an incomplete abortion, hence the diagnosis ‘incomplete, without complication’. These professionals confirmed that a O044 diagnosis is a complication arising from an incomplete abortion and should be included with the other ICD-10 codes used by OHID, O040-43 and O045-48; the clinical assessment and treatment is the same for each of these nine codes, O040-48.
Conclusion
There are no operational reasons why the OHID does not include these HES data when it publishes annual abortion statistics. The data have already been compiled by NHS Digital, so there is certainly no time constraint. Nor is there any issue related to patient confidentiality and privacy of their data; NHS Digital does not publish any patient identifiers and states clearly on these Excel files that when the numbers are small and might lead to a potential identification of an individual patient it does the following, “To protect patient confidentiality for sensitive codes, sub-national suppression has been applied or age breakdowns removed.”, as can be seen by the * in cell H5416 in the above screenshot.
Given that the OHID acknowledges that there are significant limitations with the abortion complications data that are collected using the HSA4 form and reported in the Abortion Notification System, and that it has shown that a more complete and accurate report can be generated using Hospital Episode Statistics as a supplementary source for data, and that these HES data are readily available from NHS Digital, if the government chooses not to require the 2023 reporting of abortion complications to include HES data, it would then be responsible for the deliberate under-reporting of about twelve thousand cases of treatment of abortion complications by our NHS hospitals in that year.
[i] Abortion statistics, England and Wales: 2022. (2024, May 23). GOV.UK. https://www.gov.uk/government/statistics/abortion-statistics-for-england-and-wales-2022/abortion-statistics-england-and-wales-2022
[ii] Hospital Admitted Patient care activity, 2022-23 – NHS England Digital. (n.d.). NHS England Digital. https://digital.nhs.uk/data-and-information/publications/statistical/hospital-admitted-patient-care-activity/2022-23
[iii] Complications from abortions in England: comparison of Abortion Notification System data and Hospital Episode Statistics 2017 to 2021. (2023, November 23). GOV.UK. https://www.gov.uk/government/statistics/complications-from-abortions-in-england-2017-to-2021/complications-from-abortions-in-england-comparison-of-abortion-notification-system-data-and-hospital-episode-statistics-2017-to-2021
[iv] Written questions and answers – Written questions, answers and statements – UK Parliament. (2023, November 28). https://questions-statements.parliament.uk/written-questions/detail/2023-11-28/HL662
[v] Abortion complications. Percuity. https://percuity.blog/abortion-complications/
[vi] FOI requesting Hospital Episode Statistics data on the treatment of abortion complications in England, 2017 to 2023. (2024, December 18). Percuity. https://percuity.blog/foi-requesting-hospital-episode-statistics-data-on-the-treatment-of-abortion-complications-in-england-2017-to-2023/
[vii] Hospital admitted patient care activity – NHS England Digital. (n.d.). NHS England Digital. https://digital.nhs.uk/data-and-information/publications/statistical/hospital-admitted-patient-care-activity
[viii] Hospital Admitted Patient care activity, 2023-24 – NHS England Digital. (n.d.). NHS England Digital. https://digital.nhs.uk/data-and-information/publications/statistical/hospital-admitted-patient-care-activity/2023-24
[ix] Ibid. Select this link: https://files.digital.nhs.uk/A5/5B8474/hosp-epis-stat-admi-diag-2023-24-tab.xlsx
[x] Complications from Abortions (Annual Report) Bill [HL] – Hansard – UK Parliament. (2024, December 13). https://hansard.parliament.uk/Lords/2024-12-13/debates/B4F008C3-FF51-4694-88F6-F60044E3ED58/ComplicationsFromAbortions(AnnualReport)Bill(HL)#contribution-1CC8C4BF-154D-42C3-B8FD-8A55B198B6A2
[xi] Ibid. See link 6 above for access to our FOI report.
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