The Wisconsin Medical Society submitted comments this week on proposed regulatory changes to Title X funding. Title X is a federal grant program that provides funding for family planning and reproductive health services for low-income and uninsured patients.
The U.S. Department of Health and Human Services (HHS) released the proposed rule in May, indicating that the changes are intended to correct three errors pertaining to the use of Title X funds: requirements for counseling and referrals regarding abortion, allowing the sharing of physical space for family planning services and abortion, and permitting infrastructure building when physical space could be shared.
The proposed rule also would extend HHS’s oversight of Title X funds to include subrecipients of Title X grantees and would remove the phrase “medically approved” from regulations which currently require that grantees provide medically approved family planning services.
In the comment letter, Society CEO Bud Chumbley, MD, MBA, cited existing Society policy on family planning and abortion-related services and expressed concerns related to the following: reduced access to family planning services, increased potential for adverse patient outcomes, removal of the phrase “medically appropriate” from regulations, increased administrative burdens and the potential impact on physician speech.
“The Society appreciates efforts…to clarify interpretations of the existing Title X rule as it relates to abortion, and to expand access to types of family planning services that may be preferred by patients,” the letter states. “However, these clarifications should not restrict access to existing family planning services, nor disadvantage the physicians who provide these services.”
“It has always been goal of the Society to do what is best for patients, while also respecting the beliefs and convictions of its member physicians,” Dr. Chumbley concluded. “It is the hope of the Society that HHS consider our recommendations and develop regulations that respect the rights of patients and physicians, while ensuring access to medically appropriate care.
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