NHeLP Organizes 64-Organization Letter To Support Preventive Care For Women

Executive Summary

This sign-on letter urges HHS to fully adopt the IOM recommendations regarding coverage of preventive services to meet women's unique health care needs with no cost-sharing.

Secretary Kathleen Sebelius 
U.S. Department of Health and Human Services 
200 Independence Avenue, S.W. 
Washington, D.C. 20201 
Dear Secretary Sebelius: 
We write to you to urge HHS to fully implement the recent recommendations from the Institute of Medicine (IOM) regarding preventive services for women, and to require that all of the IOMrecommended services be included in health care coverage without cost sharing. The undersigned organizations represent a diverse array of organizations committed to access to quality health care, in particular for low-income women and communities. 
The Affordable Care Act (ACA) set out baseline definitions for preventive services and, with respect to women, charged HRSA with developing comprehensive guidelines for additional preventive care and screenings. In August of 2010, your office commissioned the IOM to develop recommendations regarding the preventive women?s health services that should be added. The IOM report was issued on July 20, 2011. The IOM process included an exhaustive evidence-based review of health care services, extensive stakeholder input, and careful analysis of current coverage trends. We believe that the impeccable and commendable IOM process is reflected in the quality of the study results, and we strongly recommend that HHS fully adopt the IOM recommendations. 
Specifically, the IOM recommendations fill important gaps in the U.S. Preventive Services Task Force guidelines: all eight identified services are entirely essential to health care for women. Addressing this full range of services will not only go a long way towards improving the health of women, but it will also help begin to address health disparities affecting racial and ethnic minorities who are more likely to lack affordable access to these services and/or be disproportionately at risk for conditions that the recommendations address. We also note that increased access to many of these eight services will also help reduce long-term health care costs, which is an objective of the ACA. 
As HHS designs coverage policies around these preventive services, we encourage HHS to consider a few additional points. First, if adopted, robust coverage policies within each service category will be essential to meaningful access to the preventive services. For example, as noted in the IOM report, different contraceptive methods may have varying rates of effectiveness for different individuals. Contraceptive coverage must include all forms of FDA-approved drugs, devices and supplies to ensure that each person has access to the most effective method for her health and personal needs. 
Second, creating insurance coverage for preventive services does not guarantee that providers will prescribe or provide the services. HHS should also work to educate the provider community about the content and importance of the new coverage standards, as well as to encourage providers to make these preventive services readily available to their patients. Third, we urge HHS to implement these standards uniformly, without weakening them with exceptions to the preventive services mandates for plans that have objections to any particular preventive service. Women deserve the highest quality health care coverage designed using evidence-based standards of medical practice. This is exactly the framework that the IOM has used, and the one we support. A recent report from the National Health Law Program, Health Care Refusals: Undermining Quality Care for Women, provides an extensive analysis of the disastrous health care consequences for women when medicine is based on personal beliefs instead of evidence-based medical standards.
We realize that HHS will hear from stakeholders who will criticize the IOM recommendations. We believe, however, that the thoughtful evidence-based process that the IOM followed and the quality results achieved speak for themselves. We note also that much of the criticism aimed at the IOM recommendations ignores the simple fact that many of these services are already covered by the majority of health insurances, but they may be unaffordable to some women without the requirement that they be covered without cost-sharing. Other criticism is based on misrepresentations or inaccuracies?such as allegations that this effort is about ?free contraception? when in fact it is paid for through insurance premiums; or attempts to confuse contraception with abortion, when in fact the definition of contraception is very clear. The IOM did exactly what it was charged to do, and its recommendations should be heeded. In conclusion, we urge HHS to fully implement the IOM recommendations in light of the critical health needs of women and the comprehensive evidence-based medical standards reflected in the report. If you have any questions or need any further information, please contact Leonardo Cuello, Staff Attorney at the National Health Law Program, at 202-289-7661. 
National Health Law Program (NHeLP) 
Abortion Care Network 
Advocates for Youth 
All our Lives 
American Association of University Women (AAUW) 
American Congress of Obstetricians and Gynecologists, District IX 
American Humanist Association 
American Medical Student Association 
Antelope Valley WIC Program 
Association of Reproductive Health Professionals 
Black Women?s Health Imperative 
Breastfeeding Coalition of Solano County 
Breastfeeding Task Force of Greater Los Angeles 
California Academy of Family Physicians  
California WIC Association 
Center for Independence of the Disabled, NY 
Center for Medicare Advocacy 
Center for Reproductive Rights 
Center for Women Policy Studies 
Clinicas de Salud del Pueblo, Inc. 
Delta Health Care 
Directors of Public Health Nursing (DPHN) 
Edgerton Women's Health Center 
Florida Legal Services, Inc. 
Health Action New Mexico 
Health & Disability Advocates 
Ibis Reproductive Health 
Law Students for Reproductive Justice 
League of United Latin American Citizens 
Maine Equal Justice Partners, Inc. 
Massachusetts Law Reform Institute 
MCAH Action California Maternal, Child and Adolescent Health Directors 
Medical Students for Choice 
Michigan Consumers for Healthcare 
Migrant Legal Action Program 
National Asian Pacific American Women's Forum (NAPAWF) 
National Campaign to Prevent Teen and Unplanned Pregnancy 
National Center for Transgender Equality 
National Council of Jewish Women 
National Latina Institute for Reproductive Health 
National Network of Abortion Funds 
National Organization for Women 
National WIC Association 
National Women?s Liberation 
New Mexico Center on Law and Poverty 
New Yorkers for Accessible Health Coverage 
Ohio Poverty Law Center 
Physicians for Reproductive Choice and Health 
Preconception Health Council of California 
Public Justice Center 
Raising Women?s Voices for the Health Care We Need 
Religious Coalition for Reproductive Choice 
Reproductive Health Access Project 
Reproductive Health Technologies Project 
Riverside Family Health Medical Group 
San Diego County Breastfeeding Coalition 
Sargent Shriver National Center on Poverty Law 
SisterSong Women of Color Reproductive Justice Collective Southwest Women?s Law Center 
West Virginia Focus: Reproductive Education & Equality (WV FREE) 
Western Center on Law and Poverty 
Wisconsin Alliance for Women's Health 
Women of Reform Judaism 
Mary K. Wakefield, PhD, RN 
Sherry Glied 
Office of the Assistant Secretary for Planning and Evaluation 
Assistant Secretary for Planning and Evaluation 
Steve Larsen 
Rose Marie Martinez 
Director, Board on Population Health and Public Health Practice 

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