On behalf of the Asian & Pacific Islander American Health Forum (APIAHF), we appreciate the opportunity to comment on the Department of Health and Human Services’ proposed rule on the Title X Family Planning Program, entitled Compliance with Statutory Program Integrity Requirements (“the proposed rule” hereafter). For over thirty years, APIAHF has served as the oldest and largest health justice organization working to improve the health and wellbeing of the over 20 million Asian Americans, Native Hawaiians and Pacific Islanders (AAs and NHPIs). With 40 community-based organization partners in 27 states and territories, APIAHF provides a voice in the nation’s capital for AAs and NHPIs, who comprise the fastest growing groups in the nation. APIAHF believes that every individual, regardless of where they come from, their immigration status or the type of provider they see has the right to health and that includes whether and when to have a family.
Title X is the only federal program designed to provide family planning services to communities most in need, including those who are low-income, limited English proficient, and uninsured. Title X serves over 4 million people at nearly 4,000 clinics each year. The proposed rule runs counter to the intent and purpose of the program and would significantly block access to health care under Title X and denies women and gender non-conforming people of color complete information about their full range of reproductive health care options. This rule will have a devastating impact on women and families across the country, of which will drastically impact women of color in particular. For this reason and those expanded on below, we urge the Department of Health and Human Services to maintain the integrity of the Title X program in its current form and rescind the proposed rule.