THE Government’s impact assessments of the Terminally Ill Adults (End of Life) Bill, which returns to the House of Commons next week, make “chilling reading”, the Bishop of London, the Rt Revd Sarah Mullally, has said.
Church leaders, led by Bishop Mullally, have continued to campaign against the Bill, which seeks to legalise assisted dying, saying that its proposed safeguards are not strong enough to protect the most vulnerable in society, including the elderly, who may consider themselves to be a burden to family or society (News, 21 March).
On Friday, the Department of Health and Social Care and the Ministry of Justice published an impact assessment and an equality impact assessment of the Bill which was brought by the Labour MP Kim Leadbeater. The Report Stage is due to be debated on 16 May.
The main 149-page impact assessment estimates that, should the Bill be passed and voluntary assisted dying services introduced by October 2026, the process would result in between 164 to 787 assisted deaths in the first six months, and between 1042 to 4559 assisted deaths by the tenth year of its implementation.
The assessment includes a consideration of the economic effects of the Bill, surmising that costs and spending on palliative care, domiciliary care, care homes, state benefits and pensions, and local authorities would be reduced.
Responding on Monday, Bishop Mullally said: “It is crude to see these cost savings set out in this way, and it is easy to see how numbers of this nature could contribute to someone feeling that they should pursue an assisted death rather than receive care. Each human life is immeasurably more valuable than the money that may be saved through their premature death.
“Every person is made in the image of God and holds an irreducible value that is worthy of care and support until the end of their life. We must oppose any change in the law that puts the vulnerable at risk rather than working to improve access to desperately needed palliative care services.”
The separate equality impact assessment sets out how the Bill, as it stands, would affect certain groups, including people who are disabled, assessing capacity, susceptibility to coercion and pressure, and barriers to accessing voluntary assisted dying services.
It states: “Evidence suggests that disabled people may be more susceptible to feeling as though they are a burden on those around them. Pressure is not necessarily felt or applied by other people — disabled people may feel subtle pressure due to attitudinal barriers or a lack of alternative appropriate services and support (for example, when accessing palliative care).
“Disabled people are also twice as likely (compared to non-disabled people) to be victims of domestic abuse which includes coercive behaviour.”
In terms of gender, the assessment says that, in other jurisdictions with comparable assisted dying policies, “men have proportionately submitted more applications for assisted dying or died via these means, though this was only by a small margin. We are not able to accurately determine whether this would be the case in England and Wales.”
The careers of women are, however, likely to be disproportionately affected by the Bill, because there are significantly more women working in hospice care in England and Wales. “Women tend to disproportionately provide unpaid care and end of life care, both professionally — 91% of hospice staff in 2022 to 2023 were female (see reference 24) — and as unpaid carers,” it says. “Women may be more impacted in terms of the intersectional impact on female carers.”
Women are also significantly more vulnerable to domestic abuse, including coercive control (News, 11 April, Analysis). “We do not have evidence on how many victims of domestic abuse have a terminal illness and would or would not want to request assistance to end their own life,” the assessment says.
The Bill currently requires a “co-ordinating doctor” and “independent doctor and panel to be satisfied that the person is making their declaration voluntarily, without coercion or pressure from another person. Bishop Mullally has previously argued that coercion is too nuanced to be detected by third party safeguards.
She said on Monday: “The impact assessment of the Terminally Ill Adults (End of Life) Bill makes for chilling reading as it highlights particular groups who would be put at risk by a change in the law, including those who are subject to health inequalities, and those vulnerable to domestic abuse.”
On sexuality, the equality assessment says: “Evidence suggest that lesbian, gay, bisexual, transgender and queer (LGBTQ+) people often access palliative and end of life care services late, or not at all, due to fear of discrimination.”
Race is also assessed. “People from minority ethnic groups experience health inequalities in terms of access, outcomes and experiences,” it says, “which may extend to this service.”
On age, it says: “We have no evidence on how many terminally ill people under the age of 18 with a life expectancy of six months or less may want to access assisted dying in England and Wales. . . Elderly people, who are in all other jurisdictions the main recipients of assisted dying, are often dependent on those who care for them, putting them at increased risk of elder abuse, although we have no data on this in the context of assisted dying.”
Other factors considered include pregnancy. “As drafted at the end of committee stage in the House of Commons, a pregnant person who also meets the eligibility criteria in the bill, would not be explicitly excluded from seeking assistance to end their own life. Notwithstanding, clinicians may use their right to conscientious objection and not assist an eligible pregnant person or recent mother to access assisted dying.”
Health professionals may also consciously object to providing assisted-dying services. On mental health, the assessment says: “Having a mental illness would not exclude a person from accessing assisted dying if they are otherwise eligible.”
It concludes: “Government is neutral on this bill, however, has offered technical support on workability. If it is the will of Parliament that this bill becomes law, government will ensure that it is implemented in such a way that attempts to mitigate unlawful discrimination, harassment and victimisation and manage any equality issues that may arise.”
