Important! Please comment on the proposed new Title X regulations by 7/31

Hi everyone,

Please take a moment to write a comment to HHS on the proposed new regulations for Title X.  You must do it by July 31st.

Background:  The Trump Administration has issued new proposed regulations for the federal Title X family planning program that would make significant changes to the program and to the types of providers that qualify for funding. These proposed regulations would:

< ![if !supportLists]>·        < ![endif]>Block the availability of federal funds to family planning providers like Planned Parenthood that also offer abortion services;

< ![if !supportLists]>·        < ![endif]>Curtail counseling and referrals to abortion services by Title X funded providers;

< ![if !supportLists]>·        < ![endif]>Eliminate current requirements that Title X sites offer a broad range of medically approved family planning methods and non-directive pregnancy options counseling that includes information about prenatal care/delivery, adoption, and abortion; and

< ![if !supportLists]>·        < ![endif]>Direct new funds to faith-based and other organizations that promote fertility awareness and abstinence as methods of family planning.

< ![if !supportLists]>·        < ![endif]>Sites that do not offer abortion services may still qualify for Title X funds, but may decide not to participate because of concerns about clinical standards of care, medical liability, and burdensome administrative requirements.

< ![if !supportLists]>·        < ![endif]>If fully implemented, the proposed changes to Title X would shrink the network of participating providers and have major repercussions for low-income women across the country that rely on them for their family planning care.

 

You can submit your comment opposing these new regulations, but you only have until July 31stHere is how to do it in two easy steps.

 

< ![if !supportLists]>1.      < ![endif]>Click on this link

  Link: https://www.regulations.gov/comment?D=HHS-OS-2018-0008-0001

 

< ![if !supportLists]>2.      < ![endif]>Copy and paste these paragraphs into the comment box (or modify them as you see fit). Then follow the instructions to complete the submission as listed on the webpage.

Dear Secretary Azar,

 

I am writing to strongly oppose the Proposed Rule released by the Department of Health and Human Services entitled Compliance With Statutory Program Integrity Requirements (HHS-OS-2018-0008). The Proposed Rule would make radical changes to the Title X federal family planning program that could significantly impede access to time-sensitive and essential health care for the millions of low-income individuals that are served by the program each year. California’s Title X program is the largest and most comprehensive Title X system in the nation that serves over 1,000,000 patients at over 350 health centers throughout the state. Title X funding saves California approximately $1.3 billion annually in costs related to unintended pregnancy.  I oppose the Proposed Rule for the following reasons.

 

< ![if !supportLists]>·        < ![endif]>Patients need and deserve comprehensive information to make informed decisions about their health in a timely manner in order to achieve their reproductive goals and optimal health outcomes. If enacted, the Proposed Rule will force Title X grantees to not only withhold accurate information about abortion, but to also steer patients to providers that may not offer the treatment they need. It will also force many qualified providers to discontinue participation in the program and will result in gaps in care in regions throughout California and the country.

< ![if !supportLists]>·        < ![endif]>Title X patients must have access to comprehensive, patient-centered family planning care. The Proposed Rule allows entities to receive Title X funding even if they only provide a single method of contraception, rather than a broad range of birth control methods. Studies show that women who are able to use the method of their choice are more likely to use that method correctly and consistently, and in turn, greatly reduce their risk for unintended pregnancy.

< ![if !supportLists]>·        < ![endif]>Teens must have access to Title X providers that they can trust to provide quality, teen-friendly care in their local communities. The Proposed Rule requires Title X providers to collect and document personal and private information that could harm the relationship between doctors and patients and discourage patients – particularly teens – from obtaining essential family planning and related services. This will likely lead to increased rates of unintended pregnancy and STDs among adolescents and increased government costs.

< ![if !supportLists]>·        < ![endif]>Separation requirements must not deny Title X patients timely access to qualified providers. The extreme physical separation requirements included in the Proposed Rule will eliminate qualified providers from the Title X program. This could greatly reduce access to care. If all qualified family planning providers that also provide abortion services were to be eliminated from the Title X family planning program in California, 19 California counties would be left without a Title X-funded health center and many local health systems would find it difficult to absorb the patients left behind as a result.

< ![if !supportLists]>·        < ![endif]>Limited Title X resources must be reserved for low-income individuals in need of publicly supported family planning services. Congress established the Title X program to create a pathway for low-income and uninsured individuals to access family planning care. The Proposed Rule seeks to allow women to receive family planning services under the Title X program if their employer refuses to cover contraceptive care based on religious or moral objections, regardless of their income. Redefining “low income” to include this population will divert scarce resources away from serving the low-income patients at the heart of Title X’s purpose.

For these reasons and more, I urge you to rescind the Proposed Rule and maintain the Title X program as Congress intended, to expand access to low-income individuals in need of essential family planning services that promote public health.

 

****

 

Thanks,

Caitlin O’Connor, MPH, CHES

Title X Program Manager

UCLA OB/GYN

1010 Veteran Avenue

Los Angeles, CA 90024

P (310) 825-6657

F (310) 206-3649

caitlinoconnor@mednet.ucla.edu