Bericht der German Alliance for Choice, 4.2.2020
Due to federalism, the implementation of CEDAW in Germany is inconsistent and not coherent. The federal states must ensure a sufficient supply of outpatient and inpatient facilities for performing abortions. This is not guaranteed throughout theterritory of the State party.
The federal states are responsible for ensuring the provision of abortion care. Still, no monitoring framework exists to document whether and how they do so. The health ministries of many federal states do not have any data and figures concerning the numbers and geographical distribution of doctors providing care, much less comprehensive analysis of the situation of provision of abortion care and improvement strategies. Instead, they refer either to the Federal Medical Associations, the state Medical Associations, the professional associations of gynaecologists or to the hospital associations, who have no legal responsibility for the provision of abortion care. [...]
The states and medical associations are obliged to provide the Federal Statistical Office with names and addresses of the facilities where abortions have beenperformed or where German Alliance for Choice (GAfC), Joint Submission to CEDAW, February 2020 6 abortions are to be performed. According to information from the Federal Statistical Office, however, the federal states and chambers only fulfil this obligation very irregularly.The Federal Statistical Office has relevant data at its disposal, due to compulsory reporting requirements of abortion providers, but is not yet authorized to share it due to data protection regulations.
There is therefore no transparency on the regional situations on the part of the Federal states (exceptions are the city states of Hamburg, Berlin, Bremen). However, pregnancy conflict counselling centres have been reporting severe problems with women’s access to abortion care for years, e.g. in Lower Bavaria, Rhineland Palatinate, Northern Hessen, Lower Saxony. From 2003 to 2018, the number of centers (which could be doctors’ office or medical institutions) reporting that they perform abortions has decreased by about 43% (from 2050 to 1.170 reporting centers).
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