June 28, 2018
Dear HHS Secretary Azar,
The Wisconsin Alliance for Women’s Health (WAWH) is writing to express our opposition to the Department of Health and Human Services’ proposed HHS-OS-2018-0008-000, which would enforce a "gag rule" on health care providers that participate in the Title X federal family planning program. WAWH advocates for women and families across the state of Wisconsin, many of whom depend on Title X funded services to access the healthcare they need. WAWH has serious concerns about how this rule will adversely affect women’s health in our state and across the country.
Title X is an important health care program that provides approximately 31,000 Wisconsin patients a year with access to essential services like birth control, cancer screenings, and other preventive care. If not for Title X funded services, many of these women and men would not have access to this care. The network of Title X funded providers is particularly critical in largely rural states like Wisconsin, as these providers are often the only affordable option, or the only option for such services, in several of the communities they serve.
If implemented, the Department’s proposed rule will either deny many low-income Wisconsinites who rely on Title X funded services access to care completely or compromise the quality of care they receive from Title X providers. The rule would lead to these results for three reasons.
First, the proposed rule would impose new regulations that are designed to make it impossible for patients who rely on Title X funded services to get birth control or preventive care from reproductive health care providers that also provide abortions, such as Planned Parenthood. This is particularly problematic in Wisconsin, as Planned Parenthood serves 86 percent of our state’s Title X patients. There is no feasible provider network in Wisconsin that would be capable of absorbing the patients who rely on Planned Parenthood to provide them with Title X funded care. In fact, Wisconsin patients have already suffered at the hands of similar state-level restrictions when our Governor and Legislature blocked all state funding from Planned Parenthood, which lead to the closure of five rural, family planning health centers in Wisconsin. No other provider has stepped up to serve these patients, meaning thousands of women, men and young people lost access to critical preventive health care like sexually transmitted infection (STI) testing and treatment, cancer screenings, and birth control. These service cuts were the result of a state funding prohibition that created a $1 million dollar shortfall. Should Planned Parenthood of Wisconsin lose all of its Title X funding, it would face a shortfall of $3.5 million and thousands of Wisconsinites would likely have nowhere else to go for this essential care. The effects of this proposed policy will likely be similar in other states, too.
Second, the Department’s proposed “gag rule” allows health care providers to withhold medically accurate and necessary information regarding abortion from patients who request that information directly. This is not only unethical, but harmful to the provider-patient relationship, patient health, and the public health. All patients in Wisconsin, regardless of where they access care, deserve the fundamental right to be able trust their healthcare providers in order to receive accurate and comprehensive information that is necessary for these patients to make informed health care decisions.
Lastly, this rule would prohibit health care professionals from referring their patients for abortion care, even in cases where such care is necessary for the health of the patient or requested by the patient. These last two provisions rob women of the right to make informed health care decisions and can even endanger their personal health in cases where an abortion is necessary to protect the health of a pregnant woman.
Because of the negative affects this rule would have on the health of patients and the professional standards of a wide swath of health care provider fields, the medical community overwhelmingly opposes this proposal. WAWH strongly recommends that the Department pay close attention to the concerns raised by organizations and individuals that are dedicated to providing essential care to the individuals who rely on Title X funded services. The concerns raised by those in the medical community are premised on the longstanding principle that when patients access any type of health care, they should have access to the best care and information available. This proposed rule runs afoul of this basic tenet of medical ethics. As a result, the Department should heed the widespread opposition to this rule and withdraw this harmful proposal.
Thank you very much for your time and consideration regarding this important matter.
Wisconsin Alliance for Women’s Health
Sara Finger, Executive Director