October 26, 2017
Dear Acting Secretary Eric Hargan:
Thank you for the opportunity to provide comments on the Department of Health of Health and Human Services’ (HHS) Draft Strategic Plan FY 2018-2022. As an organization that advocates for policies that promote the optimal health and security for women and girls in Wisconsin, the Wisconsin Alliance for Women’s Health (WAWH) strongly opposes any health policies or objectives that will limit women in Wisconsin from accessing critical health care.
It is also imperative that HHS, the nation’s foremost health policy organization, understand and orient all its activities on a foundation firmly centered in science. The HHS Draft Strategic Plan falls far short of this requirement by deviating from accepted science while introducing religious and other non-scientific prohibitions on essential care. HHS should put women’s needs first by working with physicians, the experts on patient care needs, rather than relying on the ideological interests of individuals and groups.
As you further refine the Draft Strategic Plan and as the Department puts this plan into action in the coming years, I urge you to make the following recommended changes that are critical to women’s health:
Ensure women have continued access to preventative primary care service as is provided under the Affordable Care Act.
The HHS strategy does not do enough to ensure that women have access to evidence-based preventive services. Section 2713 of the Affordable Care Act (ACA) enabled women to access preventive services with no cost sharing. Since implementation of the law, more than 62 million women now have coverage of women’s preventive services with no cost sharing.
We urge HHS to add “contraception” to the list of preventive services named in the strategy to expand access to healthier living supports, and support access to contraception as a preventive service for all women, regardless of their employer.
Access to contraception reduces unintended pregnancies and the need for abortion, and saves federal dollars. No-copay coverage of contraception has improved the health of women and families and contributed to a dramatic decline in the unplanned pregnancy rate in the United States, including among teens, now at a 30-year low. Women with unplanned pregnancies are more likely to delay prenatal care, and infants are at greater risk of birth defects, low birth weight, and poor mental and physical functioning in early childhood. Increased access to contraception is an American success story, enabling women to reach their professional and educational goals, and improving economic stability for women and their families. HHS should take steps to protect women’s access to all preventive services, including contraception, without cost sharing, regardless of their employer’s beliefs.
Ensure that the HHS Draft Strategic Plan supports policies that are in the best interest of overall women’s health and specifically women’s reproductive health.
We support HHS program and initiatives that serve and protect all individuals across the lifespan. Public health programs and policies must be based on research, evidence, and medical and health-related facts, and must be responsive to individual patient and consumer needs and wishes. However, we note that r
We are concerned that HHS is inserting concepts such as “the unborn” and life “from conception” into its strategic plan. These concepts run contrary to medical and health-related evidence and standards of care, and instead reflect one particular religious point of view that has no role in advancing and protecting the public health of a diverse population. Elevating a fertilized egg to equal status with a person is contrary to U.S. law and establishes a policy framework that would undermine the ability of women and others to make the best decisions for themselves and their families, including decisions impacting their health and wellbeing, and their ability to participate in public life. Such policies will impede the ability of HHS to cultivate and inform best practices for women’s health, and in turn, interfere with the ability of providers, particularly those who offer reproductive health services, to provide quality care to their patients.
In addition, one of the basic functions of government is to ensure the health and well-being of its population. Privileging embryos and fetuses over people threatens the capability of HHS to fulfill this function, and would deprive women of health care benefits that medical and health care experts recognize as critical to ensuring women’s health and wellbeing. Elevating the status of a fetus over the health needs of pregnant women would result in poorer maternal health and poorer birth outcomes. Moreover, adopting policies that give health rights to fetuses would also undermine a woman’s constitutional right to access abortion, and interferes with the patient-provider relationship by limiting the information, counseling, referral and provision of abortion services that a woman can receive, despite the fact that these are part of the standard of care for a range of common medical conditions including heart disease, diabetes, epilepsy, lupus, obesity, and cancer. The language is overly broad, confusing, and subject to misuse and abuse by creating a federal health care framework that invites HHS to refuse to participate in the orderly delivery of evidence-based health care services.
Remove all language that either promotes open-ended deference to religious entities or is unscientific and non-medical language that threaten women’s access to the full spectrum of health care services.
HHS should not prioritize the beliefs of religious and faith-based groups over the health care needs of my patients. The Draft Strategic Plan states that HHS will “promote equal and nondiscriminatory participation by faith-based organizations in HHS-funded or conducted activities,” (Line 361) and HHS will “affirmatively accommodate” burdens imposed on the exercise of religious beliefs and moral “convictions” by persons and entities partnering with HHS (Objective 1.3, Line 368). We urge that you to strike every mention of such language, which invites limitations on health care access based on non-medical religious or moral grounds.
The American Congress of Obstetricians and Gynecologists (ACOG) opposes federal, state and local legislation and regulations, hospital policies, and business decisions that threaten to create restrictive circumstances for patients and clinicians. Prohibitions on essential health care based on religious or non-scientific grounds jeopardize women’s health and safety. Where health care services are legally restricted based on religious or moral grounds, health care providers are required to withhold needed care, risking the health and life of their patients and deeply harming the sanctity of patient-physician relationship. The Draft Strategic Plan’s repeated commitment to accommodating faith-based entities alarmingly signals that HHS is prioritizing opinions and beliefs over scientifically based access and care needs. HHS should put patient care first and strike all language that promotes religious or ideological beliefs over my patients’ right to basic health services.
Along the same lines, as the nation’s health policy center, HHS policy and activities must be firmly based on scientifically valid and appropriate terms and evidence. The Draft Strategic Plan defines an individual’s lifespan from “conception” to “natural death” and identifies the goal of HHS as improving healthcare outcomes “for all people, including the unborn” (Strategic Goal 1, Line 115). “Conception” and “unborn” are lay terms that have no scientific validity and are generally not used in or by the medical community. Find the correct scientific definitions here.
Reliance on unscientific and non-medical terms threatens women’s access to essential reproductive health services, including birth control, assisted reproductive technology (ART), stem cell research, in vitro fertilization, and abortion. WAWH supports patients’ decisions on whether to have children, the number and spacing of their children, and to have the information, education, and access to health services to make these choices. Abortion is a necessary component of women’s health care and HHS should not support politically imposed barriers to abortion access.
As a result of the concerns articulated above regarding the HHS Draft Strategic Plan, we respectfully request that changes are made to this plan. We appreciate the opportunity to provide comments on the negative impact this plan would have on Wisconsin women.
Executive Director and Founder
Wisconsin Alliance for Women’s Health
Take Your Own Action and Submit Comments Now
Cecely Castillo, Policy Director