DC--Center for Inquiry

The Center for Inquiry urges Centers for Medicare and Medicaid Services (CMS) to clarify in your final rule on Medicare benchmark benefit plans that certain types of plans must include coverage for family planning services in order to be approved by the Secretary of Health and Humans Services (HHS). The Center for Inquiry (CFI) is a transnational organization which promotes and defends science and reason as a basis for public policy and therefore supports reproductive freedom, of which family planning is an essential component. More than 7 million women, or 12 percent of women in the U.S. aged 15-44, rely on Medicaid and related public programs for health services. The rule as it stands now would allow states to exclude family planning services from alternative benefit packages, severely limiting access to family planning services for women in those states. To protect access to these basic preventive services, we urge CMS:  To clarify in §440.330 that Secretary-approved coverage for women of reproductive age can only be considered “appropriate for the population” if it includes family planning services and supplies, and  To designate in §440.335 family planning services and supplies as “appropriate preventive services” that must be covered in any benchmark-equivalent plans offered to women of reproductive age. The December 3, 2008, defined acceptable coverage as anything approved as “appropriate for the population” by the HHS Secretary, and did not require that family planning services be included. This rule undermined the emphasis on family planning that characterized Medicaid for over 30 years. On behalf of women who rely on Medicaid for family planning, we urge you to revise your definition of acceptable coverage as outlined above. Sincerely Toni Van Pelt Government Affairs Director