NCHR Comments on HHS Draft Strategic Plan FY2018-2022

U.S. Department of Health and Human Services

Office of the Assistant Secretary for Planning and Evaluation

Strategic Planning Team

200 Independence Ave. S.W.

Room 415F

Washington, D.C. 20201

 Attn:   Comments on the HHS Draft Strategic Plan FY 2018-2022

October 26, 2017

Dear Acting Secretary Eric Hargan:

Thank you for the opportunity to provide comments on the Department of Health and Human Services’ (HHS) Draft Strategic Plan FY 2018-2022.  The National Center for Health Research (NCHR) analyzes scientific and medical data and provides objective health information to patients, providers, and policymakers. We do not accept funding from the drug or medical device industry, so we have no conflicts of interest.

Our Center supports health reform policy and care delivery policies that are rooted in sound science and objective data. We strongly oppose the language and themes of the Draft’s goals and objectives connoting moral or religious value judgement or objections to essential care. The HHS must ensure the health of our Nation, and must make policies based on objective medical and public health science. We urge that HHS bring evidenced-based practice into the forefront of health policies.

As HHS further refines the Draft Strategic Plan and implements its goals and objectives in the coming years, we provide the following recommended changes:

#1. Remove language which places a subjective value judgement against non-traditional families or social relationships.

Today’s America is made up of a diversity of families and social relationships. Terms like “healthy marriage” (lines 887, 1025) or “healthy family formation” (line 1020-21) should be used with great care, because families that seem healthy to the outside world can nevertheless be extremely unhealthy in terms of family violence, sexual exploitation, drug abuse, and other issues.  We agree that America’s youth requires guidance, and support programs that promote healthy transitions to adulthood.  These policies ought to promote healthy parent-child relationships regardless of parental marital status. Policies should encourage youth to pursue healthy behaviors with the understanding that what is healthy for one person is not necessarily the best path for someone else.

#2. Remove language which places a preference on vague religious objectives over medical science and public health.

The draft’s Goal 1 objective to expand choice and services is repeatedly punctuated by the term “faith-based” (lines 316, 333, 375, 390). We agree that public health programs can be delivered via faith-based community organizations. However, a federal agency should not “affirmatively accommodate” the “beliefs and/or moral convictions” as a priority above delivery of equitable and evidence-based care to all persons regardless of religion or belief (lines 367-368). Policies must not deny or restrict medically necessary services based solely on religious or moral objections. Furthermore, terms such as “unborn” (line 115), “conception” (lines 61, 830, 846, 1143, 1334) and “natural death” (lines 831, 847, 1144 ) are non-scientific and should not be used by our country’s public health agency. We urge you to strike out all such language.

#3. Ensure that vital women’s preventive health services are part of the plan to “increase access.”

Currently, the preventive services discussed in objective 2.1 (lines 538-541) focus on maternal health, which we agree is an important area of need. However, we strongly urge contraception to be included as a vital preventive service. Access to free contraception has provided 62.4 million women with a way to stay healthy and financially secure. The CDC estimates that the 2016 teen pregnancy rates dropped by 9 percent, and the Guttmacher Institute found that the abortion rate in 2014 had dropped by 14% since 2011. These trends are often attributed to free contraception that became available as a result of the Affordable Care Act.  We all agree that we want these trends to continue, and that requires continued free access to contraception for those who want it.  We urge the HHS to continue to support all women’s preventive health services, including contraception.

Thank you for your serious consideration of the above recommendations. We urge you to focus on strategies based on sound science and medical evidence, rather than ideology and political rhetoric. In this way, HHS ensures its mission and responsibility to put the public’s interest first.



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Diana Zuckerman, PhD


National Center for Health Research