Ten Reasons to Comment Opposing Proposed HHS Rule

The public comment period ends tomorrow on the HHS proposed rule on “physician conscience!” Go here to submit your comment. We’ve written a number of posts on the issue, as has RH Reality Check if you need to catch up on the proposal.

Here are 10 reasons to submit your comment opposing the regulation:

1. Federal law already protects providers from being forced to perform abortion as it is defined by the medical community.
2. The leaked draft made clear that an attempt to allow broad and inconsistent definition of “abortion” was underway. The official proposal doesn’t bother to define abortion or what services could be refused, despite being specific enough to define “workforce” and “individual.”
3. Low income, rural, and otherwise underserved women are likely to be disproportionately affected by reductions in access to care.
4. There is no provision to require providers to notify women up front of which services they won’t provide, talk about, or provide referrals for.
5. There is no provision to require that care be provided despite “conscience” objections when other access is unavailable or to protect the woman’s health.
6. Secretary Leavitt has either lied about or doesn’t understand the ob/gyn certification issue he has used as justification for the proposal, despite ABOG’s clear explanations.
7. The proposal extends the definition of healthcare “providers” to an absurd extreme, including administrative or support roles such as the personnel who clean instruments.
8. The proposal is unnecessarily vague on some issues, such as whether Medicaid providers (of care to low-income women) are exempt – it lists an exemption for Medicaid, and yet goes on to say that states should ensure the compliance of Medicaid providers.
9. Issues such as those in points 2, 7, and 8 above are likely to lead to inconsistent application and enforcement of the proposed rule.
10. Last but not least, this is simply yet another attempt to limit women’s access to legal and necessary healthcare.

David Castillo at RHRC has five additional reasons you should also read.

Don’t forget to comment – tomorrow’s the last day!