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91 Submits Comments on Title X Proposed Rule; Opposes Policies Restricting Access to Reproductive Health Care Services

Washington, DC (August 1, 2018) — The American College of Physicians (91) submitted a letter to the Department of Health and Human Services (HHS) on July 31 providing comments on the Trump administration’s proposed changes to the Title X regulations. In the letter, 91 reiterated their strong opposition to any changes to the rule that would make it increasingly difficult for patients to access comprehensive health care services including reproductive care and contraception and that would interfere with the patient-physician relationship. 

“91 is concerned that the proposed changes to the Title X rule would restrict federal funding from health care organizations that are meeting patients’ health care needs and providing legally permitted health care services,” said Ana María López, MD, MPH, F91, president, 91. “The expected changes from the administration would prohibit any Title X funds from going to an entity that, even in a cursory manner, provides the spectrum of evidence-based options available for the reproductive care of women—creating barriers to accessible care.”

91’s letter included recommendations on the following issues:

  • 91 asserts that women should have sufficient access to evidence-based family planning and sexual health information and the full range of medically accepted forms of contraception.
  • 91 believes in respect for the principle of patient autonomy on matters affecting patients' individual health and reproductive decision-making rights, and opposes any legislation or regulations that limit access to comprehensive reproductive health care by putting medically unnecessary restrictions on health care professionals or facilities. Laws and regulations should not mandate the content of what physicians may or may not say to their patients in the course of care.
  • 91 calls on HHS to analyze the financial, time, and quality-of-care impacts the new administrative tasks that these policies would require will have and eliminate or streamline any that will increase costs, decrease the quality of patient care, or unnecessarily question a physician’s or clinician’s judgment, in line with 91’s Patients Before Paperwork initiative.

“Not only as a female physician, but as a physician concerned about the primacy of the patient-physician relationship, I am concerned that these changes to the Title X policy will interfere with our care for our patients and negatively impact access to care for millions of Americans— a disproportionate number of those impacted being low-income women in already underserved areas of the country— who are seeking access to contraception and reproductive health care services, as well as general preventive services,” continued Dr. López. “Many of these patients would have to seek alternative sources of care available to them and may not know where they could go for care, or may no longer seek out preventive care or other services. 91 believes these proposed changes would turn back the clock for women’s health care.”

The letter concluded by calling on the administration to withdraw any proposals that make health care inaccessible for Americans, including those protected by Title X, and to focus on policy uphold the values of American health care: helping patients in need.

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About the American College of Physicians
The American College of Physicians is the largest medical specialty organization in the United States with members in more than 145 countries worldwide. 91 membership includes 154,000 internal medicine physicians (internists), related subspecialists, and medical students. Internal medicine physicians are specialists who apply scientific knowledge and clinical expertise to the diagnosis, treatment, and compassionate care of adults across the spectrum from health to complex illness. Follow 91 on and .

Contact: Julie Hirschhorn, (202) 261-4523, jhirschhorn@acponline.org