Can you send--if you think appropriate--to FAB list?
Karen
-----Original Message-----
From: Delacey Skinner [mailto:[log in to unmask]]
Sent: Monday, April 08, 2002 3:48 PM
To: Delacey Skinner
Subject: NAPW Seeks Comment on Federal Unborn Child Rule
Dear Friends and Allies,
We last contacted you in February to let you know that the Department of
Health and Human Services had announced their intention to expand the State
Child Health Insurance Program (S-CHIP) to include prenatal care by
redefining a fetus as a child. As we mentioned then, when a new regulation
is proposed, the government must provide an opportunity for public
commentary before putting it into place.
The time period for public commentary on this particular regulation has
begun. We are asking everyone who is concerned about expanding fetal rights
language and about wasteful government action to write a letter indicating
their opinion about this measure. We encourage you to make your letters your
own; please address any aspect of the proposed regulation that particularly
concerns you. For background information, we have included some talking
points below. We also urge you to read the proposed regulation itself, which
you can find at:
http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=2002_register
<http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=2002_register&doc
id=02-5217-filed> &docid=02-5217-filed.
It is actually quite a short and interesting political document.
Comments must be made in writing, in letter format. Letters/comments are
due by May 6, 2002, at 5:00 pm. In your letter, they request that you refer
to file code CMS-2127-P. They will not accept comments by facsimile (FAX)
transmission. Please mail written comments (one original and three copies)
to the following address ONLY:
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-2127-P, P.O. Box 8016
Baltimore, MD 21244-8016
Please feel free to pass this request and information along to other
individuals who may be interested in sending comments. Because we are
interested in you comments, we would also appreciate it if you would send a
blind e-mailed copy of the letter to us, as well at
[log in to unmask]
<mailto:[log in to unmask]> .
Thank you.
S-CHIP Expansion Comment Letter Talking Points
-- Changing the definition of a "child" to include "individuals in the
period between conception and birth" is an obvious political effort,
unrelated to real efforts to improve the health of actual children, pregnant
women, or mothers.
--Rather than waste efforts to reach an admittedly tiny percentage of either
children or fetuses (30,000), the Department of Health and Human Services
should be making efforts to address the cutback in funding for existing
children (see "Society Will Pay the Price of Cutbacks," by Neal Halfon and
Peter V. Long, Los Angeles Times, March 3, 2002.)
--Medical experts agree that the best path to a healthy baby is a healthy
pregnancy, in which the woman's health care needs are the highest
consideration. Treating the fetus as if it exists separately from the
pregnant woman implies that the health of the fetus not only can, but should
be considered before the health of the woman carrying it. This conflict
often leads to medical choices that benefit neither the woman nor the fetus.
--These rules reflect a fundamental disrespect for women and mothers. Under
these rules, coverage is extended only to the fetus, not the woman, so any
injury or disease she suffers that does not directly affect the pregnancy
will not be covered. Nor will she, according to these rules, be covered if
she suffers a miscarriage or stillbirth, as more than 900,000 women do each
year.
--The section of the proposed regulation regarding fetal surgery falsely
suggests that there are forms of health care that could apply exclusively to
a fetus, separate from the woman carrying it. There is no form of fetal
surgery that does not require cutting into a woman's body, therefore putting
her health at risk and requiring her consent. Moreover, these trial forms of
intervention have, thus far, resulted in few successes and are, at best,
considered experimental.
--A far better plan for increasing prenatal care access would be to grant
state waivers across the board that would allow pregnant women of any age to
be covered under S-CHIP. Alternatively, the Administration could throw its
support behind a bipartisan bill, sponsored by Senator Jeff Bingaman, which
not only adds pregnant, adult women to the list of those eligible for CHIP,
but it also provides funds to pay for their care. Under the Administration's
current plan, many women would not receive coverage simply because states
across the country are running out of funds and cutting back coverage under
their existing CHIP programs.
--We urge the Department of Health and Human Services not to implement this
regulation, which, by redefining the term child , reduces women to vessels,
undeserving of the most basic level of health care. We urge you to focus,
instead, on addressing the health care needs of the millions of Americans
without health care coverage and on health care approaches that respect
women's rights and treat them as full human beings.
Lynn M. Paltrow
Executive Director
National Advocates for Pregnant Women
45 West 10th Street #3F
New York, New York 10011
212-475-4218
212-254-9679 (fax)
[log in to unmask] <mailto:[log in to unmask]>
www.advocatesforpregnantwomen.org <http://www.advocatesforpregnantwomen.org>
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