Document Type: Proposed Rule
Title: Ensuring Access to Equitable, Affordable, Client-Centered, Quality Family Planning Services
Document ID: HHS-OS-2021-0010-0001

The Vermont Medical Society would like to voice our strong support for the Biden-Harris Administration’s recently proposed regulations to end the Title X gag rule. The 2019 rule prohibiting providers from referring patients for abortion was completely counter to the trust necessary to establish a strong patient-provider relationship. This rule forced all Vermont providers to withdraw from this funding, which made access to quality health care more difficult in our rural state and put low-income Vermont women at risk of foregoing reproductive health services and other preventive care.

The Vermont Medical Society applauds the proposed rule change aimed at strengthening the program and better ensuring access to equitable, affordable, client-centered, quality health care services for low-income patients under Title X. As we have witnessed throughout the pandemic, access to quality health care is ultimately an equity issue that has resulted in ongoing health disparities for the most vulnerable in our communities. The gag rule slashed the Title X network’s capacity to deliver family planning services and other essential health care to uninsured and low-income Vermonters. Whereas Vermonters with private insurance were permitted to receive full family planning counseling. In Vermont, roughly 50 percent of the thousands of women who benefitted from expanded family health care services due to Title X had incomes at or below 100% of the federal poverty level and 75% of these women had incomes at or below 250% of the federal poverty level.

In many areas in our rural state, Title X providers play a critical role in providing direct patient care that otherwise would not be available. In Vermont, the Planned Parenthood health clinics that previously received Title X funding also played an essential role in ensuring access to contraceptive care and counseling, STI testing and treatment, HIV services, cancer screenings, and other preventive health care. Without Title X funding for family planning services there will be more unintended pregnancies and higher health care costs in Vermont. Title X supports critical infrastructure needs that are not reimbursable under Medicaid and commercial insurance, such as individual patient education, community-level outreach, and public education about family planning, women’s health, and sexual health issues.

Vermont taxpayers are currently backfilling the funding necessary to deliver the services that the funding provided through Title X previously supported. Therefore, the Vermont Medical Society urges you to please lift the gag rule under Title X and help all women have access to the full array of reproductive health care services.