Michigan Consumers for Healthcare signed onto a letter along with the National Health Law Program and other organizations urging the US Department of Health and Human Services (HHS) to fully implement the recent recommendations from the Institute of Medicine (IOM) regarding preventive services for women.
The letter is as follows:
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 IOM-recommended 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 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.