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AAMC Comments on Title X Proposed Rule

August 3, 2018

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PRESS CONTACTS
Phoebe Ramsey, Sr. Regulatory Analyst, Quality & Payment Policy

The AAMC July 31 submitted comments on the Department of Health and Human Services (HHS) proposed rule, “Compliance With Statutory Program Integrity Requirements” revising Title X program regulations.

In its comment letter, the AAMC urged HHS to withdraw the rule as proposed because of concern that the proposal would undermine standards of medical professionalism, harm patients who rely on Title X providers as an essential source of their health care, and add burdensome requirements without commensurate benefit.

Title X of the Public Health Service Act established grants for providing lower income patients with family planning and preventative health services and information. HHS proposed to revise some of the regulations regarding these Title X grant projects, including banning Title X-supported providers from giving patients full information on their health care options.

The AAMC raised concerns that such a policy is incongruous with the standards of medical professionalism and long-held standards of the ethical practice of medicine founded upon informed consent. Additionally, the AAMC commented that the proposed policies would undermine access to evidence-based medicine, could jeopardize the demonstrated success of the Title X program in contributing to the decline in the rate of unintended pregnancies in the United States, and could harm patients who rely on Title X-supported providers for their health care.

The AAMC also commented that the proposal would add onerous reporting requirements for Title X grantees based on the mere possibility of the funds being used for prohibited activity and would extend grantee liability well-beyond what is reasonable, counter to the administration’s efforts to reduce regulatory burden.

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