CMA Delivers Statement to Institute of Medicine
March 09, 2011
As part of the implementation of ObamaCare, the Institute of Medicine held three hearings to assist HHS in determining what “preventive services” for women will be mandatory for all health insurers and insurance plans to provide (with no upfront costs to patients). A decision is due in August 2011, and there have been many loud voices advocating for contraception.
John F. Brehany, Ph.D., Executive Director of the CMA, attended the March 9 meeting of the Institute of Medicine's Committee on Preventive Services for Women and was able to deliver the statement below, which was entered into the record of the Committee's proceedings:
Institute of Medicine Committee on Preventive Services for Women
The Keck Center, 500 Fifth Street, NW
Washington, D.C. 20001
March 9, 2011
The Catholic Medical Association (CMA) is the largest association of Catholic physicians in the United States, made up of members representing over 75 specialties in medicine. As executive director, I would like to address the issue of whether contraceptive services should be classified as a “preventive service” for women and, ipso facto, become a mandated health insurance benefit.
Designating contraceptives as “preventive services” would fail tests of logic and sound science. “Preventive services,” by definition and as designated by the U.S. Preventive Services Task Force, prevent serious disease, dysfunction and/or injury which would require treatment to restore health or function. Fertility is a natural feature of human nature, not a dysfunction; and pregnancy is a natural human condition, even if not always planned or desired. Abortion cannot be considered a preventable cure in terms of ethics, medicine, or law.
Designating contraceptives as “preventive services” does not constitute good clinical medicine. Hormonal contraceptives can pose significant risks to otherwise healthy women. These risks are not confined to a small set of women exhibiting particular disease or behavioral histories. Rather, an extensive body of evidence shows hormonal contraceptives pose substantial threats to women, including myocardial infarction, cerebrovascular accidents, depression, deep venous thrombosis, pulmonary emboli, cervical cancer, and liver cancer. The relationship between OC use and breast cancer—and in particular the disturbing connection between OC use and triple-negative breast cancer (for which OCs raise the risk by 2.5 to 4.2 times depending on age )—should cause caution and concern. Moreover, the increase in aggressive breast cancer following widespread use of HRT, which utilizes the same hormones found in OCs, is well documented. This experience should rule out any effort to expose more women to these synthetic hormones. Designating contraceptives as “preventive services” would give the false impression that these are safe and standard medications. Moreover, to the extent that widespread use of contraceptives contributes to sexual promiscuity, it contributes to a range of significant impacts to the health and well-being of individuals and communities.
Promoting and mandating contraceptives in order to reduce unplanned pregnancies has failed in the past and will fail in the future. Despite decades of such advocacy, despite millions, if not billions of dollars spent in the effort, and despite the fact that 35 states already mandate contraceptive coverage as a part of prescription drug coverage, the Guttmacher Institute still reports that nearly half of all pregnancies among American women are unintended and that 54% of women who have abortions had used a contraceptive method during the month they became pregnant.
Mandating insurance coverage of contraceptives is not only a failed strategy, it is also unfair and unethical public policy. Such a mandate would force people to subsidize specific interest groups and businesses, including Planned Parenthood, who would benefit from having contraceptive coverage mandated. It would force people to subsidize contraceptives, and the behaviors they enable, even if they have ethical objections. It would increase the likelihood of ethical conflicts in health care, particularly for providers who object to dispensing contraceptive services based on religious beliefs or moral convictions. Such ethical conflicts would be exacerbated by the improper designation of abortifacients as contraceptives. For example, HRA Pharma’s ulipristal acetate, known as “ella,” was approved by the FDA as an “emergency contraception,” despite the fact that it is essentially similar in chemical structure and modes of efficacy to the abortion drug RU-486. If such abortifacients were mandated as preventive services, this would violate the letter and spirit of the Patient Protection and Affordable Care Act, the express terms and legislative history of which exclude abortion and abortifacients.
In sum, the CMA believes we should use our limited funding and resources to provide real preventive services that promote, rather than harm, women’s health.
A PDF version which includes citations is available here.