In response to the March 9, 2009 Presidential Memo on Scientific Integrity: Request for Public Comment
Federal Register /Vol. 74, No. 77 /Thursday, April 23, 2009, p. 18596
Submitted May 13, 2009, by electronic mail to email@example.com
These comments are respectfully submitted by the
Association of Reproductive Health Professionals
For nearly 50 years, the Association of Reproductive Health Professionals (ARHP) has established itself as the leading source for trusted medical education and information on reproductive and sexual health. ARHP is accredited by the Accreditation Council for Continuing Medical Education (ACCME) to provide continuing medical education to health care providers through a variety of educational programs, meetings, and publications. Our membership is composed of member professionals who provide reproductive health services and education, or conduct reproductive research. ARHP members are key community leaders who are poised to advocate for evidence-based policies that can improve patient care and access to health care services.
On behalf of its 11,000 health care provider members, ARHP applauds all efforts to restore scientific integrity to all federal agencies and supports federal policies that are based on the best and most unbiased scientific information. ARHP offers the following as the reproductive health care provider community’s values and priorities:
- Scientific integrity is the foundation for policy decision-making, health care research, and translation of research into health care practice
- Excellence in education for health care providers is key to the best possible patient care
- The health care team is the future of service provision in the United States
- Reproductive health science and research are critical and highly valued ingredients to everyone’s life throughout their lifespan
- Everyone has the right to and the need for access to comprehensive, high quality reproductive health care services including:
- abortion care
- sexual and reproductive health education and information services
- pre- and post-natal care
- prevention, screening, and treatment services for HIV/AIDS
- prevention, screening, and treatment services for reproductive cancers
- assisted reproductive technologies
We also ask for leadership and action on the following:
Restore Scientific Integrity to the Nation’s Health Care Programs
- Appoint credible leaders who value evidence-based decision-making to lead the various federal health agencies under your purview in order to restore scientific integrity and government credibility with the public.
- Ensure that all federal health agencies, including the FDA, CDC and NIH, prioritize science over politics and are committed to women’s health issues.
- Instruct the FDA to review and evaluate the scientific data underlying the age restriction on over-the-counter access to Emergency Contraception (EC) to ensure that the FDA’s policy is based on sound science rather than politics.
Increase Access and Remove Barriers to Family Planning and Reproductive Health Services
- Ensure women’s specific reproductive health and medical needs are considered when crafting new policy to make health care more affordable and accessible to all.
- Take immediate steps to reverse the HHS Federal Refusal Rule. This rule will obstruct access to reproductive and other health services, counseling, and referrals and could open the door for more widespread health service refusals.
- Fix the birth control pricing crisis that resulted from change in the Deficit Reduction Act (DRA) by taking no-cost regulatory action that will restore incentives to provide affordable birth control at college health centers and certain safety net providers.
- Remove barriers to family planning services under Medicaid by suspending and revising regulations that will implement parts of the DRA to maintain “freedom of choice” protections for family planning services.
- Restore Medicaid reimbursements for birth center facilities by c larifying that birth centers are eligible for reimbursement in order to protect critical pregnancy- and delivery-related care for low-income pregnant women reversing the Bush Administration’s recent attempts to deny federal Medicaid reimbursement for birth center facility charges in several states.
- Address barriers to health care for immigrants created by the citizen documentation requirements by ensuring that CMS issue a “Dear State Medicaid Director” letter that creates a “good cause” exemption allowing Medicaid coverage during the citizenship verification period, and gives states flexibility to determine what documentation is sufficient for establishing eligibility.
Invest in Improving Reproductive Health Care Delivery in the United States
- Prioritize health care provider education as a strategy for improving the nation’s health. Promote accountability in continuing medical education to ensure the best patient care and medical practice.
- Ensure that all health insurance covers women’s access to contraceptives, abortion care, and sexually transmitted infection (STI) prevention, treatment, and counseling services, including the HPV vaccination.
- Direct the Deputy Assistant Secretary for Population Affairs (DASPA) to review Title X guidelines to ensure that they are consistent with the current evidence based best practices and standards of care for clinical, education, and counseling services and to allow the flexibility to deliver client-centered care.
- Direct the Agency for Healthcare Research and Quality, in conjunction with professional medical societies and consumer groups, to conduct a systematic, evidence-based review of best practices for improving pregnancy outcomes, including recommendations for improving the quality of maternity care and birthing practices for all women and a review of research findings on fertility services and pre-term labor prevention.
Lend Your Leadership to Educating U.S. Decision-Makers and the Public about the Influence of Reproductive Health Care on Individuals and Society
- Undertake a targeted effort to raise public awareness about the benefits of reproductive and sexual health science and research on individual’s lives, throughout the lifespan, by openly affirming the importance of scientific and technological advancements in reproductive health care services, information and delivery from childhood through adulthood. Eliminating the stigma around reproductive and sexual health should be a central goal of these efforts. These efforts may also be part of a broader effort to restore favorable attitude toward science and technology by educating the public, policy-makers, and the media about the valuable role science plays in people’s lives.
- Link reproductive and sexual health, specifically the impact of contraceptive provision and use, to the reducing and eliminating some of the world’s most pressing challenges; high rates of maternal morbidity and mortality, global poverty, economic health and security, national security, child welfare, public health and well-being, climate change and the environment. An individual’s ability to plan and space his or her children is inextricably linked to the health and well-being of individuals, communities, economies, and the earth.
- Prioritize resources, funding, and political will for reproductive and sexual health science and research as an avenue to address and minimize health disparities. These efforts should consider the ways in which disparities including race, ethnicity, immigration status, education, socioeconomic status, disabilities, sexual identity and religious background affect people’s sexual and reproductive health. This research should focus on both eliminating barriers to access to care and the delivery of culturally competent care to justly respond to health disparities.
- Examine, through research and evaluation, the complex cost benefits of access to reproductive health care and services and its impact on people’s ability to live productive lives and enjoy a stabilized economy. Nationally, for every $1.00 spent to provide services in the nationwide network of publicly funded family planning clinics, $4.02 is saved in Medicaid birth costs that are averted. 1 Recent published research shows that the direct medical costs of unintended pregnancies in the United States were estimated to be $5 billion a year, while direct medical cost savings due to contraceptive use were estimated to be $19 billion. New research should examine the health care and productivity savings associated with readily available and affordable contraception access, the economic and environmental impact of contraception, and the role of scientific advancements in reproductive and sexual health on our nation’s efforts to restore the economy and reform the health care system.
- Prioritize resources, funding, and political will for research on the linkages between reproductive health and the environment. These efforts should focus on both the affect that exposure to environmental toxins and certain chemicals have on reproductive health and fertility as well as the impact that access to comprehensive reproductive and sexual health services and information, in particular, contraception, can have on our environment. Reproductive and sexual health science and research can assist health care providers in educating the public on these issues as a way to advance social justice, healthy lives and a healthy planet.
About Audrey Kelly, PharmD