The decision by the Department of Health and Human Services (HHS) to mandate coverage of contraception and sterilization is troubling. From unjust discrimination against those who find sterilization or contraception to be morally offensive, to the increasing health costs that this Institute of Medicine (IOM) recommendation will bring, the ramifications of the HHS guideline are far-reaching. Perhaps most startling, however, is the way that the HHS, along with the IOM, has blatantly misled the nation. With the support of inadequate research, these organizations have foisted a policy upon the country that has little to do with protecting the health of the population. Instead, by gathering a committee of aggressively pro-choice advocates, and by hiding behind a shroud of purported scientific objectivity, they have pushed a “health” program that actually furthers a radical political agenda. Such partisanship is not shocking, of course, and would warrant little comment if the effects were less universal or severe.
The center of the controversy surrounding the report lies in the committee’s Recommendation 5.5, which reads: “Women will have access to all Food and Drug Administration-approved contraceptive methods, sterilization procedures, and patient education and counseling.” Supporters of Recommendation 5.5 have repeatedly claimed that its inclusion was based upon the compelling evidence of science and medicine “that greater use of contraception within the population produces lower unintended pregnancy and abortion rates nationally.”
The Guttmacher Institute, for example, claimed that the recommendations were “developed after an exhaustive review of the scientific evidence.” Kathleen Sebelius, Secretary of HHS, argued that “these historic guidelines are based on science and existing literature, and will help ensure women get the preventive health benefits they need.” Such bald appeals to scientific support highlight the brazenness of the committee’s activism. In using this cover, the committee has attempted peremptorily to label its opponents as anti-scientific.
But when we examine the committee’s methodology, especially as it touches upon Recommendation 5.5, there is ample evidence that the members of the IOM committee did not, in fact, consider the findings objectively. Indeed, we find that the members were ideologically committed to their outcome, and that Recommendation 5.5 is a skewed representation of the relevant science. Regardless of one’s particular stance on the issues at stake in this official mandate, it is a matter of great concern when those who are charged with the protection of our public health neglect that trust in preference to political activism.
The professional credentials of the Preventive Services Committee members are impeccable, but also ideological. Prior to being appointed to the committee, each member held prestigious positions in universities or in other government committees, and they have published over a thousand articles and scientific studies. It would be irresponsible to dismiss their findings with claims of incompetence. The fact that most of the members of the committee have been actively involved in abortion and contraception advocacy groups, however, did not go unnoticed by critics of the committee’s decision. In a letter of July 27, 2011, Michael O’Dea, executive director of Christus Medicus Foundation, wrote to Sebelius, “It is clear that the Institute of Medicine has an agenda. Virtually all of the Women’s Preventive Services committee members are affiliated in some way with Planned Parenthood.” Further research by HLI America has substantiated O’Dea’s concern, revealing that many of the committee members have strong relationships with both Planned Parenthood and NARAL Pro-Choice, and have actively supported pro-abortion candidates for public office.
The vast majority of the committee members demonstrate a more than casual commitment to the goals of the abortion lobby. In fact, according to information available from the publicrecord, these committee members have donated a total of $116,500 to pro-choice organizations and candidates. Public records show that not one of the fifteen committee members has financially supported a pro-life political candidate. This committee was purportedly assembled for the purpose of providing outside, objective, and expert advice to the HHS policymakers. Whatever one thinks of the relevant issues, one would be hard-pressed to argue that this IOM committee is politically nonpartisan.
Of course the political involvement of the members does not necessarily invalidate the findings of the IOM. Nor does support for a pro-choice candidate necessarily indicate an unalloyed loyalty to a cause. Yet the unbalanced makeup of the IOM’s supposedly objective committee—a makeup that does not reflect the distribution of either the lay population or of the medical community in America—should raise questions about the objectivity with which they undertook their mission.
The committee held three “open information-gathering sessions” to receive expert testimony regarding the preventive services that should be mandated and funded. However, nearly all of the invited speakers were known advocates of contraception and abortion on demand. Michael O’Dea notes:
At both meetings, the invited speakers represented organizations which advocate coverage of contraception, without cost sharing of expenses. Those organizations include the Guttmacher Institute, the American Congress of Obstetricians and Gynecologists, and the Association of Women’s Health, Obstetric and Neonatal Nurses, Planned Parenthood, The Kaiser Family Foundation and the Society for Family Planning.
Furthermore, there was not one representative from the Catholic health care system, despite the fact that it constitutes the single largest provider of health care in our country. Representatives of the pro-life and pro-family organizations (who were forced to seek permission to speak) were relegated to the brief public comments portion at the end of the day. This relegation is significant, for though the use of contraception by American women during child-bearing years is widespread, support for publicly funded contraception is not. As indicated by a recentRasmussen poll, 46% of Americans do not support the committee’s recommendation, and only 39% of Americans believe that contraception should be covered free-of-charge. This diversity of viewpoints should have been reflected in the makeup both of the committee and of the speakers invited to testify at the hearings. Instead, there was a built-in bias in support of the provision of contraception, sterilization, and abortion-inducing drugs.
This lack of objectivity was confirmed by Dr. Anthony Lo Sasso, the lone member of the committee who dissented from the IOM report. In a recent interview, Dr. Lo Sasso confirmed that “the standards of evidence that were used and put forward by the committee” fell short of a truly comprehensive and objective analysis of the data, which “allowed the committee to bring about what they wanted.” In his official dissent, Lo Sasso wrote:
The committee process for evaluation of the evidence lacked transparency and was largely subject to the preferences of the committee’s composition. Troublingly, the process tended to result in a mix of objective and subjective determinations filtered through a lens of advocacy. An abiding principle in the evaluation of the evidence and the recommendations put forth as a consequence should be transparency and strict objectivity, but the committee failed to demonstrate these principles in the report.
This critique, from a member of the committee itself, is damaging to the IOM committee’s credibility. It confirms the cavalier way in which Sebelius’s advisory group used its position to promote an ideology.
Even without the information provided by Dr. Lo Sasso, however, the report itself exhibits its authors’ biases. In support of the report’s claim “that greater use of contraception within the population produces lower unintended pregnancy and abortion rates nationally,” only two sources are cited—one of which is a non-peer-reviewed advocacy report. This spurious source was published by the Guttmacher Institute, the former research arm of Planned Parenthood and a strong advocate for abortion and contraception. One reason for this dearth of evidence is simple: Numerous studies show that greater access to oral contraception and emergency contraception does not, in fact, reduce unintended pregnancies or abortion. Such studies were conducted by the likes of Peter Arcidiacono of Duke University and Chelsea Polis of the Johns Hopkins Bloomberg School of Public Health, and have been published in journals including the Journal of Health Economics, ObstetricsandGynecology, and the Journal of the American Medical Association.
A survey like this reveals that conclusions are far from unanimous regarding the effect of oral contraceptives on unintended pregnancy and abortion rates. However, the report produced by the IOM reflects neither this uncertainty nor the weight of evidence suggesting that access to oral contraception has little to no effect at a population level. The data are homogeneous, however, in regard to emergency contraception, and point to a conclusion directly opposed to that of the IOM committee. All told, the studies reveal that while there are many “professional and editorial opinions” that emergency contraception should be made readily available, and “professional projections” that it could reduce unintended pregnancies, I have been unable find a single study indicating that it is actually effective in reducing unintended pregnancies or abortions in real population groups.
All of this seems to prove Dr. Lo Sasso’s contention about the lack of transparency in the methodology of the report; because the data were “filtered through a lens of advocacy,” they “allowed the committee to bring about what they wanted.” Such selective research is not worthy of the writer of policy or the representative of a nation.
The HHS report’s Recommendation 5.5—“Women will have access to all Food and Drug Administration-approved contraceptive methods, sterilization procedures, and patient education and counseling”—is the only “preventive service” recommendation in the report that involves the administration of drugs and surgeries. As such, one would expect a host of other considerations to arise around it: specifically, concern for the health risks associated with those drugs or surgeries. Very little attention, however, is given in the report to the risks associated with Recommendation 5.5. In the one paragraph in the 210-page report that addresses them, the committee brushes aside the higher death rates of women who smoke and use oral contraception, despite the fact that one in five American women runs this risk. Instead, the report claims that “side effects are generally considered minimal.” Such a sweeping statement demands detailed argumentation and support; instead, at this point, the report’s slim research becomes threadbare. The evidence for the report’s claim consists of three “educational pamphlets” from the American Congress of Obstetricians and Gynecologists (ACOG) and one other dated study.
This unprofessional documentation should alarm the observant reader on either side of the table. The public was repeatedly assured, upon Sebelius’s passage of the mandates recommended by the IOM, that the report was an “exhaustive review of the scientific evidence.” Yet one of the cruxes of the committee’s argument—and one which directly impacts the health of millions of American women—is sustained by educational pamphlets. Interestingly, the pamphlets themselves state that “the average readability level of the series … is grade 6–8.” These promotional brochures do not cite even one study. The report also places a great deal of emphasis on an ongoing study that has not been published and that the committee hopes will show that oral contraceptives can be a primary prevention for ovarian cancer. Selective use of potentially sympathetic findings from ongoing studies is a clear sign of a subjective bias.
The committee should have studied more rigorous peer-reviewed studies concerning the potential negative side-effects of chemical contraception. For years, medical journals have published studies that indicate the deleterious side effects of oral contraception. Peer-reviewed studies published in the most prestigious medical journals indicate that breast cancer risks are significantly higher for oral contraceptive users, particularly those women who begin contraceptive use before their first full-term pregnancy, women who have a family history of breast cancer, and women who smoke. Stroke risk is also much higher for users of oral contraception, with studies showing a 1.5–4.0 times greater risk of stroke in women who use oral contraceptives. Findings indicating a risk for stroke associated with oral contraceptive use have been published in journals that include Journal of the American Medical Association as well as Stroke: Journal of the American Heart Association. Blood clots, too, are a significant risk for women who use oral contraception, as the Physician’s Desk Reference makes clear: “An increased risk of thromboembolic and thrombotic disease associated with the use of oral contraceptives is well established.” Earlier this year, the FDA announced a safety review of the most popular oral contraceptives on the market (Yaz, Yasmin, and Beyaz) in response to recent studies that show that these drugs bring a two-to-three-times greater risk of arterial clots compared to the already high risk associated with other forms of oral contraceptives. Finally, studies prove that oral contraceptive users have a greater risk of heart attack than non-users, and that their arteries develop plaque at a faster rate. If a woman has other contributing risk factors, her susceptibility increases drastically.
Our public health officials have failed us—in the politically uniform committee selected to advise Sebelius and HHS, in the lack of integrity with which it carried out its research, and in the way it has recklessly put the health of millions of American women at risk. The FamilyResearchCouncil summed up the situation very well: “This decision completely ignores opinion, research and science that do not support a pro-abortion ideology.” Many organizations and individuals have raised similar concerns, but their words have fallen on deaf ears. However, there is compelling evidence that Recommendation 5.5 was all but predetermined, and was motivated by ideology rather than the objective standards of science and medicine or the true health needs of women.
It is, perhaps, not surprising that political maneuvering and ideology have been obstacles to HHS’s purported goal of securing the health of the American people; we do not expect completely disinterested policymaking in our democracy. What is surprising, however, is the audacity with which the committee circumvented professional research practices in order to arrive at the conclusions they held at the outset. The officials of the Department of Health and Human Services are appointed to carry out the research that the general citizenry has neither the time nor skill to pursue; they are not appointed to misguide and misinform. We must be able to trust profoundly in the integrity of those to whom we delegate these important tasks. By misrepresenting the relevant data, the IOM committee and HHS Secretary Sebelius have betrayed the trust of the American people, and have potentially put the health of millions of women at risk.
Arland K. Nichols is the National Director of HLI America, an educational initiative of Human Life International. More information can be found here at http://www.hliamerica.org.