PRCH Comment on Abortion Coverage Exclusion from High-Risk Insurance Program

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Re: Pre-Existing Condition Insurance Plan Program Federal Register: July 30, 2010 (Volume 75, Number 146) Page 45013-45033 As physicians who are experts in reproductive health, we, the undersigned, know that abortion is an essential part of comprehensive health care for women, particularly for those with pre-existing conditions like heart disease or cancer. We strongly object to the decision by the Department of Health and Human Services to withhold insurance coverage for abortion from pregnant women in the Pre-Existing Condition Insurance Plan (PCIP) program. This decision will damage patients’ health and their families’ economic stability for no medical reason. We urge the department to remove abortion from the list of excluded services outlined in Sec. 152.19(b) of the PCIP program. Without coverage for abortion services, many women and families will suffer devastating consequences. The department must reverse this dangerous discrimination against pregnant women, their spouses, and their children.
If abortion coverage is not allowed in the high risk pools, many women whose health is already compromised will be harmed. The purpose of the PCIP program is to provide comprehensive health coverage for women and men previously denied insurance coverage due to their medical history. We see this as a critical step forward for these patients’ well-being, both physically and financially—and abortion services must be a covered benefit. Many of the women who will be eligible to buy a PCIP policy will be able to do so because they suffer from chronic medical problems, such as diabetes, hypertension, kidney disease, autoimmune conditions, clotting disorders, cancer, and congenital heart disease. Pregnancy can seriously exacerbate each of these conditions, giving women in the PCIP program an acute need for safe, affordable abortion. As physicians, we have witnessed and studied the harmful effects of withholding abortion care from women. For those whose health is compromised by the conditions listed above, continuing a pregnancy may cause permanent physical damage or death.
The story of Marie, a pregnant lupus patient, shows the dangers for women who lack abortion coverage. Many of us have treated women like Marie, a woman with lupus who needed an abortion when she developed dangerously high blood pressure and cardiac failure during her fourth month of pregnancy. Marie might have survived pregnancy and childbirth, only to be left with serious health problems, such as stroke or kidney damage. These conditions would have made it difficult to care for herself and her
children. The PCIP program is designed for patients like Marie and thus must cover all of their health needs, including abortion. Almost every obstetrician working in a major hospital has seen a woman die from complications of pregnancy. We have also saved women’s lives by ending pregnancies when the patients’ conditions worsened. Our cumulative experience shows that women, particularly those with preexisting health problems, must have abortion as an affordable, feasible option for staying healthy. Moreover, the abortion procedures for the women eligible for a PCIP almost always require expensive hospital stays. The point of the PCIP program is to prevent economic catastrophe for high-risk patients. Pregnant women, like the rest of the patients eligible for the program, should not be forced to choose between their physical and financial health.
Comprehensive health coverage for women must include abortion services. Every woman, whether or not she qualifies for the PCIP program, has reproductive needs that vary enormously over the course of her lifetime. Many women need a range of medical care to stay healthy during their reproductive years, including birth control, vaccination, cancer screening, testing and treatment for sexually transmitted infections, prenatal care, pregnancy termination, and menopause treatments. To deny women any one of these services is to ignore the reality of their health needs. One in three American women will have an abortion by age 40, making it one of the most common medical procedures in the United States. Women seek abortions for a variety of reasons, including health conditions that worsen with pregnancy, developmental problems with the fetus, and the inability to care for a child. Any insurance program that purports to cover women’s basic health needs must include abortion services as a covered benefit. As medical professionals, we ask the department to protect women’s health in the PCIP program. Don’t put vulnerable patients at even higher risk. As obstetrician/gynecologists, family physicians, internists, and experts in family planning and maternal/fetal medicine, we recommend that the Department of Health and Human Services remove abortion from the list of excluded services under the PCIP program. Abortion is an integral aspect of reproductive health care, and an essential service for women with underlying medical conditions. We urge the department to prioritize sound medicine and quality health care. Don’t let the PCIP program hurt pregnant women and their families. Sincerely, The Board of Directors Physicians for Reproductive Choice and Health 2
Douglas Laube, MD, MEd, Chair Suzanne T. Poppema, MD, Immediate Past Chair Nancy L. Stanwood, MD, MPH, Secretary Michelle Staples-Horne, MD, MS, MPH, Treasurer Anna Altshuler, MD, MPH Frances Batzer, MD, MBE Fredrik F. Broekhuizen, MD Darcy Broughton Daniela Diaz Alison Edelman, MD, MPH Eve Espey, MD, MPH Michelle Forcier, MD, MPH Patricia T. Glowa, MD Pratima Gupta, MD, MPH Margaret E. Johnson Baylson, MD Atsuko Koyama, MD, MPH Stephanie Kusko Cramer, MD Larry Leeman, MD, MPH Sara Buchdahl Levine, MD, MPH Connie Mitchell, MD, MPH Willie J. Parker, MD, MPH Ralph Riviello, MD, MS Roger Rochat, MD Cathy J. Lazarus, MD, FACP, At-Large Member Jodi Magee, President/CEO, Physicians for Reproductive Choice and Health
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