ACOG template for comments on the HHS Draft Strategic Plan

Are you outraged by the HHS draft strategic plan, which defines life as “beginning at conception”?  Below gives information on what you can do about it.



Paula Tavrow



Hello all,


The American Congress of Obstetricians and Gynecologists (ACOG) has created a template to submit comments about the HHS draft strategic plan. You can find these comments below and in the word document attached.  


We focus on three main concerns:

1)      The use of non-scientific language (i.e. “conception” and “unborn”)

2)      The prioritization of religious beliefs over patient health care needs

3)      Protecting access to preventive women’s health services


To make sure your comments are counted, we urge you to submit them by MIDNIGHT, on Thursday, October 26th. You can submit comments by sending an email to You can copy and paste the comments directly into the body of your email, or add your name to the attached word document and send as an attachment. (Please remove the highlight!)  For reference, you can read the full HHS Draft Strategic Plan 2018-2022 here.


Please don’t hesitate to reach out to us if you have any questions. Feel free to forward to others who may be interested in submitting comments.


Thank you,



Mallory Schwarz
Manager, Federal Affairs
American Congress of Obstetricians and Gynecologists




U.S. Department of Health and Human Services

Office of the Assistance Secretary for Planning and Evaluation

Strategic Planning Team

Attn: Strategic Plan Comments

200 Independence Ave. S.W.

Room 415F

Washington, D.C. 20201



VIA FAX – (202)690-5882


Attn:      Comments on the HHS Draft Strategic Plan FY 2018-2022


October XX, 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 ob-gyn, I strongly oppose any

health policy or objectives that deviate from accepted science, as well as religious or other non-scientific prohibitions on essential care.  Women must have access to scientifically based health care.


It’s 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, as detailed below. HHS should put patients’ 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:


1.       Remove unscientific and non-medical language that threatens women’s access to the full spectrum of health care services.

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. As an ob-gyn, I support my 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.

2.       Remove all language promoting open-ended deference to religious entities, and commit to putting patients first.

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). I urge 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, like myself, are required to withhold needed care, risking the health and life of our 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.

3.       Ensure women have continuity of access to preventive primary care services as provided under the ACA.

As an ob-gyn, I see every day how important access to preventive health services are to my patients and strongly support HHS’ strategy to increase access to women’s preventive services (Objective 2.1, Line 538). 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.

HHS must do more to ensure that women achieve access to evidence-based preventive services. I 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.


Thank you for your serious consideration of my recommendations and perspective as you move forward in revising the HHS Draft Strategic Plan.  I urge you to work closely with the American Congress of Obstetricians and Gynecologists and other physicians and to base all strategies on science and medicine, rather than ideology and political rhetoric. In this way, HHS ensures its plan and actions put patients first.