NHS Female Sterilisation Policy: The FOI Disclosure Says the February 2026 Policy Was Based on 2024 Work — So Where Is the Evidence of Reform?

A note about my conclusions: this article distinguishes carefully between “there is no evidence this happened” and “the ICB did not disclose evidence that it happened.” Where records have not been supplied, I do not automatically claim they never existed. I am asking a more basic accountability question: if senior NHS leadership says these actions were completed and the records exist, why were those records not produced in an FOI specifically asking for evidence of compliance?

What did I actually ask NHS Thames Valley ICB for?

My Freedom of Information request was deliberately titled:

I was not asking for another assurance that the NHS had learned lessons. They pulled the wool over people's eyes in the media attention that exploded after the Ombudsman's report.

But I wanted the paper trail.

I asked for the final decision and approval material, equality assessment, clinical and legal rationale, evidence relating to the NHS Constitution and relevant guidance, consideration of bodily autonomy and informed choice, comparison with vasectomy, and — crucially — evidence that the revised policy-development processes introduced after the Ombudsman investigation had actually been applied.

I also deliberately asked that, if those improved processes had not been completed before the February 2026 policy was approved, the ICB provide the recorded justification, timetable and plans for completing them.

That last part matters enormously now.

What does the ICB's own FOI response admit about the February 2026 policy?

This is, in my view, the most important part of the entire disclosure.

The evidence they disclosed clearly states:

the February 2026 policy “was based on a recommendation from SERPC in December 2024” and “does not reflect process changes adopted since February 2026.”

The response also says that SERPC-04 v1.0 was recommended in December 2024 and therefore would not reflect the findings or recommendations of the PHSO report - with provisional views which they received in August 2025, and the final report published in December 2025.

That changes the question completely.

The February 2026 policy was introduced after the Ombudsman investigation had already exposed serious problems in the previous decision-making process.

But the ICB's own response now confirms that the policy adopted in February was still based on the December 2024 SERPC work.

The January 2026 Quality Oversight Group paper says the commissioning position had undergone its “full evidence review” at SERPC in December 2024. The supporting documents listed for adoption were likewise the December 2024 report, the old SERPC Equality Impact Assessment and the related supporting information.

What post-Ombudsman evidence is not in the disclosure?

I do not see disclosed:

• a new post-PHSO evidence review;
• a new post-PHSO equality assessment;
• a post-PHSO comparison of the male and female sterilisation pathways;
• a post-PHSO legal analysis;
• a post-PHSO NHS Constitution analysis;
• a post-PHSO autonomy/informed-consent analysis;
• a new consultation exercise;
• the documented SERPC feedback on the PHSO findings;
• the 10 February 2026 SERPC record showing how those findings were considered before ratification;
• the 11 February 2026 SERGG record;
• a revised decision rationale showing why the therapeutic LARC trial remained justified after the Ombudsman's findings;
• or the actual completed decision/ratification record showing what QOG members decided and on what evidence.

And their response actually admits one especially important absence: the requested female-versus-vasectomy comparison was not conducted in the 2024 supporting material.

That is significant because one of the Ombudsman's findings concerned the failure to consider female sterilisation fairly and consistently alongside male sterilisation.

So what did CEO Nick Broughton say had been done?

This is where the story becomes much more difficult for the ICB.

The claims made by CEO Dr Nick Broughton in his letters to me and to the Ombudsman after the PHSO investigation about work said to have been completed were not supported by the documents supplied in my explicit FOI request seeking to establish evidence of compliance with the revised policy-development processes.

Some things are corroborated. Some were explicitly still “in progress”. But for a striking number of actions described as completed, documented or formally agreed, the documents that should evidence those claims were not supplied in my FOI disclosure.

And you'd understand my cynicism now - but while we laugh off the ''Picture or it didn't happen''  when people make selfies in important life moments - I ask for EVIDENCE - or it didn't happen! Because we have an established and shockingly long record of CEO Nick Broughton making claims he cannot support with Evidence. 

So - here's the breakdown of what he has claimed in his letters to myself and the Ombudsman, and what we've actually got documentary evidence for in the disclosure.

 

Date: Nick Broughton's Letters	What he said had happened or was happening	Documentary evidence actually supplied in FOI-TV-2606-105?	My assessment
13 January 2026	PHSO report had been sent to the Third Committee chair/admins on 2 January, who were preparing it for dissemination to the committee.	No underlying email, circulation record, acknowledgement or dissemination record supplied.	❌ Claim only in Broughton’s letter.
13 January 2026	The ICB would “comply fully” with the PHSO recommendations.	The later disclosure expressly says SERPC-04 v1.0 was based on the December 2024 recommendation and therefore would not reflect the PHSO findings/recommendations.	⚠️ The disclosure materially undermines any suggestion that the February policy itself represented full substantive implementation.
16 February 2026	Revised SERPC-04 had been ratified by BOB ICB.	A 6 January QOG cover paper requesting a virtual decision was disclosed, but I have not seen the resulting decision/email vote/ratification record itself.	🟡 Ratification is asserted and later repeated, but the actual decision record was not supplied.
16 February 2026	Providers would be notified; a GP Bulletin issued; prior-approval form uploaded, with March implementation dates.	No provider notification, GP Bulletin, Blueteq upload record or implementation confirmation supplied.	❌ No documentary proof in the disclosure.
16 February 2026	BOB asked SERPC/SERGG to circulate PHSO findings and obtain feedback on whether SERPC’s process required improvement.	No request/circulation email or feedback request supplied.	❌
16 February 2026	“All feedback received was documented” and discussed at SERPC on 10 February and SERGG on 11 February.	No feedback, 10 February SERPC minutes, 11 February SERGG minutes, agenda papers or action records supplied.	❌ This is one of the strongest missing-record issues because he expressly says the material was documented.
16 February 2026	SERPC agreed a further review of SERPC-04, including patient choice.	The FOI response later confirms that a further review happened and a refreshed report existed.	🟡 Event corroborated, underlying evidence withheld.
16 February 2026	Terms of Reference to Planning Group 24 February; policy review 14 April; draft sign-off 22 April; issue to ICBs 30 April; implementation estimated by end May.	No 24 February ToR/planning record, April agenda/minutes, 22 April circulation or 30 April issue record supplied. The FOI response confirms a refreshed April report existed but excludes it.	⚠️ They supplied the timetable in a letter, but not the records showing the work.
16 April 2026 – overarching claim	Remedial work had been “systematically recorded within an action tracker comprising 14 discrete items.”	The 14-item action tracker itself was not supplied.	❌ Major omission. This is the central record that should evidence the claimed remediation.
Action 1 – Equity considerations	Complete: updated Terms of Reference contained explicit prompt to consider equivalent procedures for both genders; ToR reviewed in March.	No updated ToR, March review record or related template supplied.	❌
Action 2 – Action logging	Complete: actions listed on April SERPC and Policy Development Governance Group agendas; details captured in trackers.	Neither April agenda, Governance Group agenda nor action tracker supplied.	❌ They identify the exact records that supposedly prove it; none were disclosed.
Action 3 – Prioritising reviews	Complete: March SERPC work programme updated to prioritise reviews where equality issues were identified.	No March SERPC work programme or minutes supplied.	❌
Action 4 – Recording decision rationale	Complete: documentation updated and in use from April; decisions to record evidence/guidance departures and equality impact.	No updated template/documentation supplied. No April deliberation record supplied. The FOI response says the refreshed April report existed, but withholds it.	⚠️ Potential evidence exists by their own admission, but it was not disclosed.
Action 5 – Ethical Framework	Complete: Ethical Framework circulated with April agenda; slides added to committee template; ongoing.	No April agenda, circulated framework, updated template or slides supplied. The only ethical material disclosed relates to the older 2024 process.	❌
Action 6 – Comparison between treatments	Complete: report templates now prompt comparative prices and offset costs.	No revised report template supplied. The FOI response also confirms that the female-vs-vasectomy comparison requested was not conducted in the 2024 material.	❌ No proof of the claimed process change; especially important because the substantive equality comparison was still missing from the February policy evidence.
Action 7 – Equity of previous decisions	In progress: previous SERPC decisions where application differed between men and women to be reviewed for equity.	No review, work paper, list of decisions or interim output supplied.	❌ No evidence supplied of progress.
Action 8 – Publication of rationale	In progress: agreement being sought from ICB representatives.	No correspondence, proposed publication framework or decision supplied.	❌
Action 9 – Context for SERPC decisions	In progress: align SERPC work programme with ICB commissioning responsibilities and budgets.	No supporting record supplied.	❌
Action 10 – Committee training	In progress: information sessions planned covering cost-effectiveness, evidence bias, NICE obligations and ethics.	No training materials, invitations, agenda or attendance record supplied.	❌
Action 11 – Patient autonomy / experience	In progress: ethical framework review scheduled for June.	No revised ethical framework or June Governance Group record supplied.	❌
Action 12 – EIA template	In progress: current Equality Impact Assessment template to be reviewed, scheduled for June.	No revised template, review paper or June decision supplied.	❌
Action 13 – Information sharing	In progress: review other regional Terms of Reference and ethical frameworks for shared learning.	No comparative review or related record supplied.	❌
Action 14 – Public consultation	To be progressed: expert advice/communications support to create a lawful, robust consultation process.	No consultation framework or completed process supplied. On 6 May, Broughton expressly acknowledged that the work had not yet been completed and that “there is no formal public consultation programme currently underway.”	🔴 Not merely absent from disclosure: Broughton subsequently confirmed it remained undone.
6 May 2026	Governance Group had discussed public engagement in February and agreed a clearer consultation approach.	No February Governance Group minutes or decision record supplied.	❌
6 May 2026	Further expert advice was being sought on consultation duties.	No advice request, advice received, legal/engagement assessment or resulting record supplied.	❌
6 May 2026	Two consultation principles had been agreed: early stakeholder engagement and early flagging of formal consultation requirements.	No policy, template or process document containing those agreed principles supplied.	❌
6 May 2026	Thames Valley would give me a meaningful opportunity to participate, with this documented in the policy governance record.	No consultation invitation or governance record demonstrating that opportunity supplied.	❌
Post-PHSO review itself	A refreshed report reflecting the PHSO findings was considered in April; comments from the SERPC legal adviser, Thames Valley ICB and SCW then raised “significant concerns”; further work happened in June and Draft v2.2 emerged.	None of the refreshed report, April deliberations, “significant concerns” comments, June deliberations or Draft v2.2 were disclosed. Instead, the ICB labelled the refreshed material “outside scope”.	🔴 The ICB itself confirms that the strongest post-PHSO evidence exists, and nevertheless did not supply it.

Important: “not disclosed” does not automatically mean “never happened”. But this Freedom of Information request specifically asked for evidence that the revised post-Ombudsman policy-development processes had been applied. Where the ICB itself identifies records which supposedly document or evidence that work, their absence from the disclosure is itself highly relevant.

Why is the January 2026 approval paper so important?

Because it shows what the February policy was actually being approved on.

The January Quality Oversight Group paper states that the female sterilisation commissioning position underwent its “full evidence review” in December 2024.

It then lists the supporting documents used for adoption:

• the draft SERPC-04 policy;
• the December 2024 Female Sterilisation Clinical Commissioning Policy review;
• the SERPC-04 Equality Impact Assessment;
• the supporting information for policy adoption;
• and prior-approval forms.

That is the documentary foundation I was actually shown for the February 2026 decision.

The paper acknowledges that the Ombudsman investigation had concluded and says an action plan was underway.

But acknowledgement that an Ombudsman report exists is not the same thing as redoing the evidence, equality, legal, ethical, consultation and decision-making work in light of its findings before adopting the replacement policy.

Indeed, the same January paper places several further governance steps after the proposed approval, including submission of an EQIA to an EQIA panel and consultation with specialist clinicians.

Where is the actual decision approving the policy?

There is another basic problem.

The January document supplied to me says:

“Virtual decision by email requested.”

It asks Quality Oversight Group members to consider approving the policy.

That is evidence of a request for approval.

It is not, by itself, the resulting decision.

I therefore asked for the actual recorded QOG approval or ratification decision: the vote, email decision, confirmation or equivalent record showing that approval occurred and what the decision-makers relied upon.

That was not in the disclosure I received.

What happened to the equality work?

The supplied SERPC Equality Impact Assessment dates from December 2024.

It says no specific patient engagement took place, identifies no missing information, concludes that no changes were necessary, and contains blank fields for the director or decision-maker and date signed.

The January 2026 QOG paper then says that further implementation work should include:

“lead EQIA submission to and approval by EQIA panel”.

So where is that EQIA?

Where is the panel record?

Where is the signed final equality analysis?

And, particularly importantly, where is the post-Ombudsman analysis comparing male and female access to permanent contraception?

Did the ICB actually compare female sterilisation with vasectomy?

The FOI response gives a surprisingly clear answer regarding the 2024 material:

That is particularly important because the Ombudsman had already identified failures in treating equivalent circumstances involving women and men fairly and consistently.

The later 14-point action list then says a review of previous SERPC decisions where application differs between men and women was still “in progress”.

So the question remains:

Where is the documentary evidence that the substantive male-versus-female equality comparison was completed before the February 2026 policy was put into force?

I have not been shown it.

Why does the later April review matter so much?

The ICB's final FOI response confirms that the genuinely refreshed review reflecting the PHSO findings came later.

A refreshed report was presented in April 2026.

After that meeting, comments from the SERPC legal adviser, NHS Thames Valley ICB and the SCW Clinical Policy Implementation team reportedly raised “significant concerns”.

The recommendation was therefore not issued at that point.

It went back for further consideration in June.

A later revised recommendation was then produced.

That matters because Dr Priya Singh subsequently told me that this later recommendation removed the requirement for women to undergo a LARC trial before sterilisation if they did not wish to consent to LARC.

So another obvious question follows:

Why am I challenging the redactions too?

The disclosure problem is not limited to missing documents.

Names and official roles of people participating in healthcare policy-making were redacted under section 40(2).

I am not seeking private addresses or personal contact details.

I am seeking transparency about who participated in decisions affecting access to NHS healthcare.

I have therefore challenged those redactions and asked the ICB to justify why the identities of officials and professional advisers acting in official capacities should remain hidden.

Why are the cost redactions particularly relevant?

Activity, expenditure and cost figures were also blacked out in parts of the disclosure.

That matters because cost and cost-effectiveness have historically been relied upon as part of the justification for limiting women's access to female sterilisation.

Where financial considerations have been used to justify restrictions on healthcare access, there is a strong public-interest reason for being able to scrutinise the numbers and assumptions relied upon.

The disclosure is also internally inconsistent.

Figures hidden in one attachment appear openly in another, including an estimated annual cost impact of £162,000 for BOB, £47,000 for Frimley, 344 admissions, £640,000 expenditure in 2023/24 and an average cost of £1,870.

I have therefore asked the ICB to disclose the underlying activity and cost information unless it can provide a specific and legally sustainable reason for withholding it.

What about the pages marked “out of scope”?

The December 2024 SERPC minutes also contain whole sections removed as “out of scope”, including:

• Fertility Preservation;
• EBI Recommendations for Urology;
• and Retired EBI Statements.

These may ultimately prove unrelated to female sterilisation.

But I am no longer prepared simply to accept entire blocks of a decision-making meeting being hidden while being told they are irrelevant.

I have therefore requested the complete text of those sections, subject only to any specific FOIA exemption the ICB can properly justify.

If they are unrelated, the documents will show that.

Why am I now asking for metadata?

Some of the disclosed records are unsigned, undated, described as drafts, or do not make clear when the version supplied was actually created or finalised.

During the prolonged FOI delay, I specifically asked the ICB to confirm that responsive documents had been preserved in their original form, including their metadata, and that nothing had been altered, destroyed, concealed or retrospectively created.

The ICB answered:

“The ICB can confirm this.”

I have therefore asked them to substantiate that assurance by providing the available creator, creation date, modification date, last-modified-by information and version/edit history for the key documents.

After an FOI response delivered two months beyond its legal deadline, I am no longer prepared simply to accept assurances about document provenance where the underlying metadata can establish the chronology objectively.

Why is this more than an FOI technicality?

Because the Ombudsman had already investigated this organisation's handling of female sterilisation policy.

The findings concerned failures involving evidence, clinical guidance, equality, consultation, transparency, decision rationale and complaint handling.

The ICB then repeatedly said that lessons had been learned.

Dr Nick Broughton said feedback had been documented.

He described a further review timetable.

He said corrective actions had been systematically recorded in a 14-item tracker.

He said equality prompts had been added.

He said decision rationale would be properly recorded.

He said the ethical framework had been brought back into committee decision-making.

He said previous decisions affecting men and women differently would be reviewed.

He described future consultation reforms.

Then I filed an FOI specifically asking for the evidence that these new processes had actually been applied.

And many of the records that should prove those claims were not supplied.

I am not saying that every missing record proves that the action never happened.

I am saying that an organisation previously criticised for poor documentation, transparency and decision-making has once again asked the public to rely on assurances while failing, in its FOI disclosure, to produce much of the documentary evidence that should substantiate those assurances.

How long did the FOI disclosure take?

I submitted FOI-TV-2606-105 on 8 June 2026.

The statutory deadline was 6 July 2026.

NHS Thames Valley ICB did not provide the substantive disclosure until 4 September 2026.

The ICB has now expressly accepted that the statutory deadline was seriously missed and that there was no legal authority for the replacement date it had proposed.

By the time I received the documents, I had spent months chasing a disclosure about whether the NHS had actually corrected failures already identified by an Ombudsman investigation.

And once the documents finally arrived, the post-Ombudsman audit trail was still largely missing.

What have I now asked NHS Thames Valley ICB to provide?

I have asked the ICB to complete the disclosure by providing or accounting for the records it has itself described, including:

• the documented February feedback on the PHSO findings;
• the February SERPC and SERGG records;
• the updated Terms of Reference;
• the April refreshed review report;
• the April SERPC minutes;
• the 14-item action tracker;
• records showing completion of the actions marked complete;
• the legal, Thames Valley and SCW comments which reportedly raised “significant concerns”;
• the actual QOG approval or ratification record;
• any completed EQIA and EQIA-panel approval record;
• the challenged redacted information;
• and the preserved metadata for the key policy-development records.

What happens next?

I have given NHS Thames Valley ICB until the end of Tuesday 15 September 2026 to provide the outstanding records and corrected disclosure or explain, item by item, why information is not held, outside scope or legally exempt.

This is not a new statutory deadline.

The statutory deadline expired on 6 July 2026.

It is simply the final practical opportunity I am giving the organisation to complete a disclosure that is already substantially overdue.

If the ICB does not provide the records, I will proceed using the evidence already available through the Information Commissioner's Office, NHS England and the other external accountability and scrutiny routes already underway.

Where can I read the evidence?

You can read the original Freedom of Information request, the delayed disclosure, the ICB's responses, my challenge to the omissions and redactions, the Ombudsman material and the wider documentary history in my Evidence Folder.

I do not expect anyone to take my interpretation on trust.

Read what the NHS said it had done. Read what it actually disclosed. Compare the two. Then make up your own mind.

Legal FOI Request Deadlines Ignored, Internal Procedural Failures Excused, Investigating Their Staff Rejected- Here's Evidence on The Accountability Vacuum Inside NHS Thames Valley ICB  Under CEO Nick Broughton's Leadership

What is PPET — and why did I expect it to investigate?

PPET stands for Public & Patient Experience Team.

Within NHS Thames Valley ICB, this is the function dealing with complaints and patient experience. The person corresponding with me was Lorri Josey, Complaints Manager, Public & Patient Experience Team, NHS Thames Valley ICB.

This distinction matters because I was not simply sending another email to the Freedom of Information team.

I deliberately went to the complaints function because what had happened was no longer only a question of whether my information request had been answered within the Freedom of Information Act.

The ICB's own Internal Review had already admitted that the statutory deadline had been breached.

The problems I wanted investigated were now organisational:

• why the statutory process had failed;
• why the ICB's own internal escalation safeguards had apparently failed;
• why the failure continued after it became known;
• how staff had handled the matter;
• how the Internal Review itself had been conducted;
• why disputed redactions had appeared in responsive records;
• why senior executives did not appear to intervene despite being directly notified;
• and who, if anyone, would be held accountable.

Those are not simply questions about whether section 10 of FOIA was breached.

They are questions about people, management, governance and organisational culture.

Why did I involve PPET before the FOI Internal Review had even finished?

On 23 July 2026, after the FOI team had repeatedly failed to respond properly to me, I requested a formal Internal Review.

But I copied PPET into the correspondence as well.

I explicitly separated the two issues.

The Information Governance team needed to examine the handling of my statutory FOI request.

PPET, I argued, should separately look at the repeated non-response, failure to remedy an acknowledged breach, lack of identifiable accountability and wider administrative and governance failures.

I was already seeing two different questions:

The first belongs to information-law processes and ultimately the ICO.

The second, in my view, belongs squarely inside the organisation's own governance and accountability systems.

Why did Lorri Josey initially say an Internal Review made a separate complaint unnecessary?

On 27 July 2026, Lorri Josey responded.

She told me PPET had checked with NHS Thames Valley ICB colleagues and had been advised that the concerns fell within the FOIA Internal Review process rather than the NHS complaints process.

Importantly, she explained that the ICB complaints process was intended for issues including:

but said that my concerns could instead:

That was the basis on which PPET declined to investigate separately.

Fine.

So I waited for the Internal Review.

Then the Internal Review happened - and I've already written about the Internal Review in this website.

And the premise of that refusal fell apart.

What happened when the Internal Review did not actually resolve the governance failures?

By 17 August 2026, the Internal Review had concluded.

It had admitted the statutory failure.

But it had not answered many of the organisational questions I had raised.

The FOI disclosure was still outstanding.

Questions remained about the ICB's failed escalation procedures.

Questions remained about disputed redactions.

Questions remained about who was responsible.

Questions remained about executive oversight.

And Mark Gittins had now told me that he would provide no further response to my substantive challenges.

So I went back to PPET.

This time I made the distinction impossible to miss.

I told Lorri Josey:

What exactly did I ask NHS Thames Valley ICB to investigate?

My formal corporate complaint on 17 August 2026 was structured around seven areas.

• Failure of the ICB's statutory and internal FOI controls.
• Adequacy and conduct of the Internal Review.
• The continuing statutory breach without an identified legal justification.
• Handling and unexplained redaction of responsive records.
• The conduct of the Internal Reviewer after I challenged him.
• Executive accountability and failure to intervene.
• The persistent absence of accountability across the organisation.

I asked PPET to register a formal corporate complaint and allocate it to a sufficiently senior and independent investigator.

I wanted the investigation to examine the people and systems involved, including Information Governance and Mark Gittins.

I also specifically asked it to establish what action had been taken by:

• Dr Nick Broughton, Chief Executive and Accountable Officer;
• Dr Priya Singh, Chair;
• and Hannah Iqbal, Chief Strategy and Commissioning Officer.

All three had been directly notified about the continuing failures.

I wanted to know what they actually did.

That is a governance investigation.

It is not an FOI appeal.

Why did Lorri Josey send me back to the ICO anyway?

On 19 August 2026, Lorri Josey replied.

She said she had "double-checked" her previous advice and received confirmation that it was correct.

The correct escalation route, she said, was the Information Commissioner's Office.

But she did not initially tell me what legislation, regulation, ICB policy or formal complaints rule she was relying upon.

I found that unacceptable.

"I have double-checked and been told I am correct" is not a transparent reason for denying somebody access to an accountability process.

Who checked?

Against what?

What provision applies?

Why?

If a public body is refusing to investigate a formal complaint, it should be able to explain the basis for doing so.

Why did I challenge the ICB's reliance on Regulation 8?

On 19 August 2026, I wrote back.

I recognised that Lorri Josey appeared to be relying on Regulation 8(1)(g) of the Local Authority Social Services and National Health Service Complaints (England) Regulations 2009.

That provision is relevant where a complaint relates to a person's right of access to information under the Freedom of Information Act.

I was not disputing the basic point that the ICO should deal with my statutory information-rights dispute.

I had already sent that part to the ICO.

My challenge was that the ICB was treating everything connected with the FOI failure as though it automatically became an information-law question.

I specifically asked the ICB to address Regulation 8(3) and explain why the separate organisational and conduct issues I had identified should also be excluded rather than dealt with through an appropriate internal process.

I did not receive a substantive answer to that point.

Why couldn't the ICO simply investigate the people and governance failures for them?

Because the ICO is not NHS Thames Valley ICB's HR department.

It is not its disciplinary function.

It is not its executive-governance function.

It is not responsible for deciding whether Dr Nick Broughton exercised appropriate leadership after being notified of a continuing statutory failure.

It is not responsible for asking why managers failed to operate the ICB's internal escalation controls.

It is not responsible for determining whether staff complied with their internal organisational duties.

It is not responsible for deciding what management action, disciplinary action, governance action or FPPT consideration should follow.

I told Lorri Josey this directly.

If the ICB's systems failed, somebody inside the NHS still has to ask why.

If PPET was not the right team, why didn't it send the complaint to whoever was?

This was perhaps the simplest question I asked.

I told Lorri Josey:

If PPET cannot investigate this, tell me who can.

Refer it.

Escalate it.

Identify the appropriate internal governance mechanism.

If the concerns involve senior executives and that creates an independence problem, send them somewhere with sufficient independence to investigate.

I identified possible routes myself, including senior independent oversight and NHS England regional governance structures.

What I would not accept was an accountability vacuum in which:

That makes no sense to me.

What do the NHS's own Complaint Standards say should happen when things go wrong?

The Parliamentary and Health Service Ombudsman's NHS Complaint Standards are supposed to create an NHS complaints culture that is open, honest and accountable.

They describe effective complaint handling as thorough and fair.

They expect organisations to give accountable responses, identify mistakes, learn from them and take action to prevent recurrence.

Guidance for senior NHS leaders says they should ensure appropriate structures exist for fair and robust complaint investigations and that learning from complaints is used to improve services.

That is the opposite of what I felt I was experiencing.

I was not seeing curiosity about how the organisation had failed.

I was seeing a hunt for the next reason why somebody else should deal with it.

Why did the ICB close the complaint instead of identifying an accountability route?

On 28 August 2026, PPET sent its next response.

This time it explicitly cited Regulation 8(1)(g).

The ICB said my outstanding concerns arose from the handling of my FOI request and therefore would not be investigated through its complaints process.

Again, my Regulation 8(3) challenge was not substantively addressed.

No alternative internal investigator was identified.

No HR route was identified.

No governance route was identified.

No independent executive route was identified.

No one was named as responsible for examining the conduct issues.

Instead, I was told:

And I was warned that if I sent further correspondence about the FOI complaint, it might be read but not responded to.

There it was again.

The same ending.

Why did this start looking like a pattern rather than coincidence?

On 29 August 2026, I wrote back and laid out the history.

This was no longer the first time I had encountered this behaviour.

Years earlier, I had challenged the original female sterilisation policy through the ICB's complaints process.

The substantive questions about evidence, equality, clinical guidance, bodily autonomy, consultation and decision-making were not properly answered.

Dr Nick Broughton, Chief Executive, eventually issued his final response and closed the internal complaint route.

I went to the Ombudsman.

The Ombudsman subsequently found that the ICB had indeed failed to properly understand and engage with key aspects of my complaint.

Then I challenged Dr Priya Singh, Chair of NHS Thames Valley ICB, about the replacement female sterilisation policy and leadership accountability.

Again, I did not get direct answers to central questions.

Eventually, she declared further correspondence closed.

Then came FOI-TV-2606-105.

The statutory deadline was missed.

I challenged the Internal Review.

Mark Gittins eventually told me that further correspondence on those questions would receive no response.

Then I went to PPET.

Lorri Josey eventually told me the matter was closed, and future emails might not be answered.

The sequence had become painfully familiar:

Once might be poor complaint handling.

Twice starts to concern me.

When I see the same behaviour through the Chief Executive, the Chair, Information Governance, an Internal Reviewer and the complaints function, I start asking whether this is how the organisation itself operates.

What happened when I gave PPET one final opportunity to identify an investigator?

On 29 August 2026, I gave the ICB one final opportunity.

I asked PPET to address Regulation 8(3) and answer one simple question:

If nobody would investigate them, I asked the ICB to say so clearly and identify the legal, regulatory or policy basis for that position.

I gave a deadline of 31 August 2026.

That date passed without the substantive answer I had requested.

Why was "in due course" no longer good enough?

On 2 September 2026, Lorri Josey wrote again.

She said she would share my email with ICB colleagues, seek further confirmation and respond:

"in due course."

At another stage of this battle, perhaps I would have waited.

By September 2026, I was done.

I had already spent years chasing this organisation.

I had repeatedly been given vague timeframes.

I had watched legal deadlines expire.

I had watched people promise answers and then fail to provide them.

I had watched correspondence get closed while substantive questions remained unresolved.

"In due course" is not a timeframe.

And I was no longer prepared to keep my life permanently open-ended around whenever NHS Thames Valley ICB might eventually decide to answer questions about its own accountability.

Why did I finally close the correspondence myself?

On 3 September 2026, I wrote to Lorri Josey for the final time.

I told her I was done waiting for NHS Thames Valley ICB to get its own accountability processes in order.

I had asked repeatedly.

I had explained the distinction between the ICO's responsibility and the ICB's responsibility.

I had identified the legislation I believed was relevant.

I had suggested alternative accountability routes.

I had given them a deadline.

I had given them another opportunity.

I had still not been told who inside the organisation would investigate what had happened.

So this time I closed the correspondence.

There is an important difference.

I was not ending scrutiny because I did not want to answer it.

I was ending an internal exchange because I had exhausted reasonable attempts to make the organisation scrutinise itself.

I would pursue the issues externally instead.

What does this repeated behaviour say about NHS Thames Valley ICB's culture?

This is where my concern has moved beyond individual emails.

Organisational culture is not what an institution writes on its website.

It is what people repeatedly do.

NHS organisations can write that they value:

• transparency;
• openness;
• accountability;
• learning;
• patient involvement;
• equality;
• and continuous improvement.

Those words are cheap.

The test comes when somebody turns up with evidence that something may have gone wrong.

Do you investigate?

Do you answer?

Do you identify who was responsible?

Do you look honestly at leadership?

Do you correct the failure?

Or do you redirect, delay, reframe, deflect and eventually stop responding?

From my experience, the behaviour I have seen across NHS Thames Valley ICB tells a very different story from the values written in its policies.

Is this what top-down resistance to accountability looks like?

In my opinion, yes.

When the same behaviour appears at multiple levels of one organisation, I stop believing that every example is an unrelated mistake.

I saw it from the Chief Executive.

I saw it from the Chair.

I saw it through Information Governance.

I saw it through the Internal Review.

I saw it through PPET.

Different people.

Different functions.

Same endpoint.

Scrutiny is tolerated until it becomes uncomfortable. Then communication is shut down.

That is my interpretation of the documentary record.

Please read it and form your own.

What happens when nobody inside an NHS organisation will investigate the NHS organisation?

You create an accountability vacuum.

And that is dangerous.

Because healthcare organisations exercise enormous power.

They decide what treatment gets commissioned.

They decide what pathways patients have to navigate.

They decide what evidence is sufficient.

They decide how equality duties are interpreted.

They decide how complaints are investigated.

They decide whether senior leadership needs scrutiny.

They handle statutory information requests about their own decisions.

If the same organisation can make the decision, investigate the decision, investigate the complaint about the decision, review its own investigation and then decide that nobody needs to investigate the governance failures exposed along the way, that starts looking frighteningly close to institutional self-policing without meaningful accountability.

Why does this matter far beyond one FOI request?

Because healthcare governance is not paperwork.

The quality of governance affects what care people can access, how quickly failures are corrected and whether dangerous decisions are caught before they hurt people.

Weak accountability creates space for poor decisions to survive.

Poor decisions can restrict treatment.

They can create inequality.

They can leave patients without care they need.

And in healthcare, failures that remain unexamined can ultimately contribute to real harm.

This is why I become angry when accountability is treated like an administrative inconvenience.

These organisations are not selling shoes.

They make decisions about people's bodies, health and sometimes their survival.

The standard should be higher, not lower.

Is the NHS good at talking about values but bad at proving them?

That is increasingly my view.

NHS documents are full of commitments.

Openness.

Transparency.

Patient-centred care.

Learning culture.

Equality.

Accountability.

Governance.

But when I ask for evidence showing those principles being applied to an actual failure, I repeatedly find something else.

I find missing records.

I find unanswered questions.

I find delays.

I find people sending responsibility elsewhere.

I find nobody apparently willing to examine the people at the top.

And eventually I find another email telling me that communication is finished.

Values are not what an organisation says about itself. Values are what it repeatedly does when following them becomes inconvenient.

Do I think this organisational culture is rotten?

Yes.

In my opinion, this is rotten.

I am not saying that every person working at NHS Thames Valley ICB is incompetent or acting badly.

I am saying that the accountability structure I have experienced appears rotten.

A healthy organisation should be able to examine itself.

A healthy organisation should not be frightened of evidence.

A healthy organisation should not make a member of the public fight through five different internal functions simply to find somebody willing to ask, "How did we fail and who needs to fix it?"

And a healthy organisation certainly should not keep ending conversations when those questions refuse to go away.

If this can happen here, how widespread is the problem across the NHS?

I cannot prove from my case that every NHS organisation behaves like this.

But I would be deeply surprised if this culture exists nowhere else.

That is exactly why external oversight matters.

NHS England.

The Care Quality Commission.

The Parliamentary and Health Service Ombudsman.

The Information Commissioner's Office.

Health scrutiny committees.

Boards.

Audit and governance functions.

All of them should be asking whether organisations are merely publishing accountability frameworks or actually living by them.

Why am I now pursuing accountability outside NHS Thames Valley ICB?

Because I have tried the internal routes.

I complained.

I challenged the Chief Executive.

I challenged the Chair.

I used Freedom of Information law.

I requested an Internal Review.

I challenged the Internal Review.

I asked PPET to investigate the governance failures.

I explicitly separated those failures from the ICO's information-law role.

I asked for an alternative internal route.

I asked for somebody — anybody — inside the organisation to take ownership of investigating what had happened.

I did not get one.

So I am no longer spending endless weeks trying to convince NHS Thames Valley ICB that it should investigate itself.

I will take the evidence to organisations whose job is to scrutinise it from the outside.

And I will continue publishing the documentary record here.

Where can I read the correspondence with Lorri Josey and PPET?

You can read my correspondence with Lorri Josey, Complaints Manager in the Public & Patient Experience Team at NHS Thames Valley ICB, together with the FOI Internal Review, leadership correspondence and wider evidence trail in my Evidence Folder.

I encourage you to read it rather than simply taking my interpretation at face value.

This is my opinion. Read what I asked. Read what they answered. Read where they stopped answering. Then decide for yourself what kind of accountability culture the evidence shows.

Sources and further reading

• The Local Authority Social Services and National Health Service Complaints (England) Regulations 2009
• Parliamentary and Health Service Ombudsman — NHS Complaint Standards
• PHSO — NHS Complaint Standards at a glance
• PHSO — Guidance for NHS senior leaders on meeting the Complaint Standards

When the Parliamentary and Health Service Ombudsman's findings about my case finally reached the media, I should probably have felt that something enormous had happened.

After years of complaining, researching, challenging NHS policy, asking questions that repeatedly went unanswered and trying to understand how decisions affecting women's bodies had actually been made, an independent investigation had finally confirmed that many of the concerns I had been raising were justified.

The story travelled quickly. It was reported by the BBC, The Guardian, CNN, The Telegraph, LBC and numerous other publications in the UK and internationally.

I am grateful that it was reported.

But I also think that the way the story was reported created a deeply misleading impression of what had actually happened.

The Headline Version Was Much Neater Than Reality

Some of the coverage said that I had “won my case”. Some described me as having “won the right to sterilisation”. Others presented the story as a woman exposing discrimination, the Ombudsman intervening, the NHS changing its policy, and therefore the problem being fixed.

It makes a very satisfying story.

It is also not what happened.

The Parliamentary and Health Service Ombudsman investigated the decision-making behind the female sterilisation policy and the way my complaint had been handled.

Its findings were significant.

The Ombudsman found that the decision-making behind the policy had failed to appropriately balance the evidence, had not properly explored relevant evidence, had failed to clearly document why the decision departed from clinical guidance, had not dealt with comparable circumstances affecting women and men fairly and consistently, and had not been appropriately consulted on.

It also found failures in the handling of my complaint, including the failure to keep me properly informed and the failure to thoroughly address the actual concerns I had been raising.

In one of the most important passages in the report, the Ombudsman said that my views about the flawed decision-making behind the policy were right and acknowledged that I had consistently set out the evidence supporting those concerns.

That mattered enormously to me.

But the Ombudsman also explicitly said that it could not determine that I personally would have qualified for NHS-funded sterilisation if those failures had not happened.

That distinction almost disappeared from the public story.

The Parliamentary and Health Service Ombudsman Is Not A Court

This is something I do not think most members of the public understand, and I certainly did not fully appreciate the implications of it when I first entered the complaints system.

The Parliamentary and Health Service Ombudsman can investigate NHS organisations, make findings of maladministration and injustice, make recommendations, require responses and escalate serious non-compliance.

But its recommendations are not legally enforceable in the way that a court order is.

The Ombudsman itself states that it does not have legal powers to force an organisation to comply with its recommendations.

That is a very important limitation.

It is also striking when compared with the Financial Ombudsman Service. If a consumer accepts a final Financial Ombudsman decision, that decision can become legally binding on the financial business.

The Parliamentary and Health Service Ombudsman does not have the equivalent power over the NHS bodies it investigates.

So when newspapers say that somebody “won” against the NHS through the Ombudsman, the ordinary reader can quite reasonably imagine something much stronger than what has actually happened.

The Ombudsman can expose a failure.

It can recommend what should happen next.

It cannot simply order the NHS to provide me with sterilisation or force an NHS commissioning body to adopt the policy I believe patient autonomy requires.

I Did Not “Win The Right To Sterilisation”

This is probably the single most frustrating misconception created by the coverage.

I did not emerge from this process holding a legally enforceable right to walk into an NHS hospital and receive sterilisation on the basis of informed consent.

That did not happen.

What happened was that the policy was subsequently changed from “Not Normally Funded” to “Funded with Criteria”.

That was an improvement.

The previous policy had relied explicitly on supposed levels of regret and the existence of more cost-effective forms of contraception as reasons not to routinely fund female sterilisation. The revised policy removed those particular eligibility arguments.

I am not pretending that nothing changed.

But what replaced the old policy still does not resolve the fundamental issue I had been fighting about.

Under the February 2026 policy, female sterilisation is funded only where informed consent has been obtained and the woman has undergone an appropriate “therapeutic trial” of Long-Acting Reversible Contraception, or where LARC is considered contraindicated or inappropriate.

So the route remains criteria-based.

It is not simply:

That is the model I have been arguing for.

Instead, a woman seeking permanent contraception can still be placed into a pathway requiring her to trial a different form of contraception first unless clinicians decide that doing so is contraindicated or inappropriate.

That is particularly difficult for me to reconcile with the very clinical guidance discussed in the Ombudsman's report, which states that women should not feel pressured into choosing LARC over female sterilisation.

A Changed Policy Is Not Necessarily A Resolved Problem

This is where I have a serious problem with the way the NHS response was subsequently presented.

There was a lot of activity.

There were revised policies, committees, discussions, implementation dates, recommendations, reviews and assurances that learning was taking place.

Those things can sound impressive when condensed into an organisational response or a news article.

But process is not the same thing as outcome.

Changing the label from “Not Normally Funded” to “Funded with Criteria” does not automatically mean that the fundamental question of autonomy has been resolved.

To me, the critical question was never merely:

“Will you rewrite the policy?”

It was:

“Will you respect a competent woman's informed decision about permanent contraception in the same meaningful way that you respect a man's?”

As of September 2026, the policy has NOT reached that point.

The Media Mostly Reported A Closed Case

This is where the consequences of the reporting became particularly disheartening for me.

A great deal of the coverage appeared to repeat, syndicate or reframe the same basic version of events.

Very few people approached me wanting to understand the years of material underneath the headline.

Many publications reported on a case involving my body, my complaint and several years of my life without ever speaking to me about what I believed remained unresolved.

That meant the neat version travelled much further than the complicated one.

Woman denied sterilisation.

Woman complains.

Ombudsman agrees NHS got things wrong.

NHS changes policy.

Woman wins.

Story over.

Except the story was not over.

The BBC South Interview Was My Attempt To Say That Publicly

When I later spoke to BBC South, one of the most important points I wanted to raise was precisely this: despite everything that had happened, I did not believe the revised policy had created genuinely equal, consent-based access to permanent contraception.

I wanted people to understand that the distinction mattered.

When a response from the Ombudsman followed, I did not feel that it really addressed the point I was making.

To me, the response appeared to move back towards whether recommendations had been acted upon and whether the NHS had gone through the expected processes.

But that was not my question.

My question was whether the outcome of those processes had actually produced equal, autonomy-respecting access.

Those are not the same question.

The Most Painful Consequence Was That Everyone Thought It Was Finished

This is the part that makes me particularly angry about the way the story was framed.

I had spent years getting this issue into the light.

Then, when it finally became national and international news, the dominant story told the public that I had effectively won.

And afterwards, nobody from a major women's rights organisation contacted me to ask whether women actually had equal access now.

Nobody from a human rights organisation contacted me to ask whether the underlying autonomy issue had been resolved.

No major charity approached me to say, “The Ombudsman has exposed serious failings. What still needs to happen?”

At least, that was my experience.

I cannot prove who might have contacted me had the reporting been different.

But I can say that the public framing made an ongoing fight look like a completed victory.

And when a systemic problem is presented as solved, there is very little reason for anyone reading about it to mobilise around fixing it.

And This Is Where The Power Imbalance Becomes Brutal

People sometimes talk about taking the NHS to court as though it is simply the obvious next stage.

But look at the reality of that.

I am one individual.

On the other side is a publicly funded healthcare system with enormous institutional resources, legal teams, governance structures and access to expertise.

An Ombudsman investigation can expose maladministration, but if the resulting recommendations do not produce the substantive change a patient believes is required, enforceable change may ultimately require legal proceedings.

And legal proceedings require resources.

England and Wales do have mechanisms for litigation involving multiple claimants, including Group Litigation Orders and representative proceedings. But there is no simple, general-purpose US-style class action through which I can announce that every woman affected by this kind of policy is automatically part of one case and then take the NHS on collectively.

Group litigation has its own procedural requirements, legal tests, individual claims, funding questions and potential costs.

So unless a law firm, insurer, funder, charity or campaigning organisation is prepared to support a case, much of the practical and financial burden of forcing the issue through the courts can still land on individual patients.

That is an extraordinary imbalance of power.

The system can make a decision affecting thousands of people using public money.

The individual affected by that decision may then have to find their own time, energy, expertise and money to challenge it.

My View Of The Institutional Conduct Is Much Harsher Than The Headlines Suggested

The media story understandably concentrated on contraception and the difference between female sterilisation and vasectomy.

But after living through this process, one of my biggest concerns is no longer simply contraception policy.

It is integrity.

I have spent years trying to establish who made decisions, what evidence those decisions were based upon, who was responsible for checking them, why questions were not answered and what happened when serious failures were eventually identified.

I have received formal assurances about processes and governance that, in my view, became extremely difficult to reconcile with the documentary record and with what the Ombudsman subsequently found.

I have repeatedly experienced responsibility disappearing into committees, departments, organisational structures and carefully worded correspondence.

My personal view of some of that conduct is not polite.

There have been times when I have experienced what I was being told as dishonest. There have been times when I have described what I was seeing as cover-up, institutional defensiveness or an attempt to make serious failures disappear into procedure.

Those are my characterisations of my experience.

I am publishing the underlying documents precisely because I do not expect anybody to accept those words simply because I use them.

Read the correspondence.

Read what I asked.

Read what I was told.

Read what the Ombudsman later established.

Then decide for yourself whether my anger is justified.

After this experience, my opinion is that I have encountered people and structures that have at times behaved as though patient rights, bodily autonomy and accountability were problems to be managed rather than responsibilities to be protected.

That is an opinion readers are entirely free to disagree with.

But public officials and healthcare leaders are entrusted with extraordinary responsibility for other people's health and lives. I believe their conduct should be capable of equally extraordinary scrutiny.

The Ombudsman's Own Findings Were More Damning Than The “Victory” Story Suggests

Ironically, describing this simply as a successful complaint can make the actual findings sound less serious.

The Ombudsman did not merely say that somebody had filled in a form incorrectly.

It found that the policy-making process had failed to appropriately balance evidence, failed to explain departures from clinical guidance, failed to deal fairly and consistently with comparable male and female sterilisation policy, and had not been appropriately consulted upon.

It found the ICB had not properly addressed the substance of my complaint.

It explicitly recognised the emotional impact of repeatedly having to pursue answers and of being left with the feeling that I was being treated as though I was not competent to make decisions about my own body.

And importantly, the report stated that, without those failings, it was more likely than not that the eligibility criteria would have been different.

That is not a trivial finding.

It raises questions far beyond my individual case.

How Many Other Women Were Affected?

This is one of the questions I still think deserves far more attention.

The policy did not apply only to me.

For years, other women living under the same commissioning arrangements were potentially encountering the same restrictions.

Most of them will never file an Ombudsman complaint.

Most will never read committee papers from 2017.

Most will never submit Freedom of Information requests, analyse commissioning policy, compare male and female pathways, challenge NHS governance or spend years trying to establish who was responsible.

They may simply have been told no.

And then gone home.

That is why I do not regard this as merely “my case”.

This Is Why I Built The Archive

If the original media coverage gave you the impression that everything was resolved, I encourage you to go further.

This website exists so that the case does not have to remain trapped inside a two-minute news report or a newspaper article.

The Chronicles tell the story step by step.

The Evidence Archive contains the underlying policies, correspondence, complaints, Freedom of Information material, investigation documents and subsequent escalations.

The Podcast offers a conversational way to follow the chronology if you would rather listen than work through the written record.

You do not have to accept my interpretation.

In fact, I would prefer that people investigate it.

If You Are A Journalist, Please Talk To Me

If you are reporting on this story now, I would ask you not to simply reproduce the headline version that appeared in May 2026.

There is much more to this case.

There is the original policy.

There is the evidence behind it.

There is the Ombudsman investigation.

There is what the NHS said it would change.

There is what it actually changed.

And there is everything that happened when I continued asking who was accountable after the news cycle had moved on.

If you want to interview me, ask questions about the evidence or investigate the story further, please visit the Contact page.

If You Want To Use This Evidence To Challenge The System, Please Do

I also want this material to be useful beyond journalism.

If you are a lawyer, researcher, campaigner, patient advocate, healthcare professional, regulator, women's rights organisation or somebody who has experienced something similar, I want you to examine what is here.

If the evidence is relevant to a complaint, investigation, legal challenge, policy review, academic work or public-interest campaign, follow it.

If a legal team believes this material can support women who were affected by the same or similar policies, I want them to look at it.

If somebody believes the conduct documented here warrants further regulatory, governance or legal scrutiny, scrutinise it.

You can read more about my position on the legitimate public-interest use of material from this archive on the Fair Use & Public Interest page.

The Story Is Still Open

The media coverage gave this case visibility, and I will always be grateful for that.

But visibility and understanding are not the same thing.

A simplified victory narrative may actually have taken urgency away from the very issue the investigation had finally exposed.

I cannot undo that coverage.

What I can do is publish the rest of the story.

The documents are here.

The chronology is here.

The questions are still here.

And so am I.