11 related complications.”109 While the RPRHA “recognizes that abortion is illegal and punishable by law,” it also explicitly provides that “all women needing care for post-abortive complications and all other complications arising from pregnancy, labor and delivery, and related issues shall be treated and counseled in a humane, non-judgmental and compassionate manner in accordance with law and medical ethics.”110 In November 2016, the DoH enacted the “National Policy on the Prevention and Management of Abortion Complications (PMAC)” (2016 PMAC policy)111 which conformed to the Committee’s recommendations in its 2015 summary report by introducing effective accountability mechanisms and establishing privacy and confidentiality safeguards.112 However, in 2018, the 2016 PMAC policy was repealed and many of its progressive elements rolled back when the DoH issued the “National Policy on the Prevention of Illegal and Unsafe Abortion and Management of Post-Abortion Complications” (2018 PMAC policy) to “provide technical guidance…[on] the prevention of illegal and unsafe abortion and the provision of quality post-abortion care in all public and private health facilities.”113 The 2018 PMAC policy was one of the first policies signed by the new Health Secretary who was a known advocate for the use of “natural” family planning methods over modern contraceptives—a stance which is similar to that advocated by conservative religious and anti-reproductive rights groups in the country.114 i. Key updates on access to post-abortion care since 2016 Proposed recommendation: For the Department of Health to strengthen the 2018 PMAC policy by providing effective complaint mechanisms for any violations with guarantees of free legal assistance and protection of the complainant against retaliatory actions. The 2016 PMAC policy contained a “penalty clause” outlining the different officials and bodies before whom a criminal, civil, and administrative anonymous complaint may be filed in case any provision of the policy is violated.115 The clause also mandated the state party to provide any complainant “free legal assistance and…protection against retaliatory actions and suits.”116 For the first time, in law or policy, the state party has made a specific and express recognition of women’s and girls’ right to file an anonymous complaint in cases of violations of their right to post-abortion care and acknowledged its obligation to facilitate women’s and girls’ access to justice in this context. However, this penalty clause was deleted in the 2018 PMAC policy which again left undefined the specific accountability mechanisms for violations of women’s and girls’ right to access post-abortion care. Proposed recommendation: For the Department of Health to strengthen the 2018 PMAC policy by clarifying that health care workers in all public and private health facilities have no obligation to report women seeking post-abortion care, and ensuring that women’s and girls’ right to humane, nonjudgmental and quality post-abortion care including their right to privacy and confidentiality are fulfilled. In the 2016 PMAC policy, the DoH emphasized the obligation of health care providers to ensure the privacy and confidentiality of women and girls seeking post-abortion care and clarified two major points (1) that there is “no law requiring service providers to report women and girls suffering abortion complications to the law enforcement authorities” and (2) that there is no civil, criminal, or administrative liability for those providing appropriate post-abortion care.117 The inclusion of these provisions was crucial to address the fear among women and girls of arrest and