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Title X Comparison: The Nation’s Family Planning Program Has Been Drastically Altered By The Trump Administration From The Obama Administration

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The Title X Family Planning Grant Process Has Been Altered Drastically From The Obama Administration Through The Trump Administration.

The Trump administration scrapped what was formerly anon-political processunder the Obama administration with their 2018 and 2019 grant announcements for the Title X Family Planning Program. Through thenew guidelines, thefamily planning program can nowreward the most extreme, anti-birth control views of its political supporters.The inconsistencies between not just the Obama and Trump administrations,but year to year under Trump's HHS,are highlyunusual and make the process difficult for most granteesto navigate. The grantees that dobenefit from such changes were explicitly kept in mind with changes such as the 2018 shift that a Title X recipient comprised of a group of partner organizations need not all provide birth control. That recipients of an already under-resourced program arenot required to provide hormonal contraceptives undermines the very mission of the family planning program.The below comparisons outline how the grant processes have changed from the Obama era to 2018 (the first year the Trump administration overtook the program); how Trump’s Department of Health and Human Services (HHS) changed the process from 2018 to 2019; and how the 2019 grant announcement compares to that of Obama’s tenure.

Title X: Obama Era Vs. 2018 Grant Announcements

Under Obama, a Title X applicant could designate subawards to execute additional family planning services that it would not provide. In 2018, the guidelines’ Program Description emphasized more explicitly how an applicant could be comprised of either a single provider or a group of providers that together provided a broad range of family planning methods — which under Trump, did not include contraceptives.

Additionally, career Regional Health Administrators were stripped of their power to make final grant award decisions, which previously existed to ensure that need, not politics, drove the process. They were replaced by the acting Deputy Assistant Secretary for Population Affairs, Valerie Huber, a political appointee who has spent nearly two-decades promoting abstinence-only, anti-birth control programs.

In short, the Trump Administration scrapped a non-political process for a family planning program that could reward the most extreme, anti-birth control views of its political supporters.

Download the PDF below for a side by side chart comparison of the 2016/2017 Title X grant process and scoring guidelines, and the 2018 issued guidelines.

Title X: 2018 Vs. 2019 Grant Announcements

When HHS released its 2018 guidance for Title X family planning grant applications, critical changes were made that negatively impacted the grantmaking process’s integrity. These changes included replacing the Regional Health Administrators — who made final grant award decisions — with political appointee Valerie Huber, an anti-birth control, abstinence-only advocate, and giving heavy weight to projects that prioritize the rhythm method.Such rollbacks remain embedded in the 2019 guidance, released in November 2018.

The 2018 guidance was also sharply criticized for failing to even mention contraception. This year’s guidance has taken a few steps to address such criticism —while also doubling down on abstinence-only education language and pushing partnerships with faith-based organizations.

While the 2018 program priorities did not mention the word “contraceptive,”they also didnot mention outright abstinence counseling (though recommendations had included “providing counseling to minors on how to resist attempts to coerce minors into engaging in sexual activities.”) The 2019 priorities, on the other hand, state that projects should offer a “broad range” of family planning methods, including “abstinence counseling, hormonal methods (oral contraceptives, rings and patches, injection, hormonal implants, intrauterine devices or systems), barrier methods (diaphragms, condoms), fertility awareness-based methods and/or permanent sterilization.”

Birth control, however, is not mentioned as 2019 key issue (nor was it last year). Instead, the key issues stress “sexual risk avoidance” as an effective means of birth control; advocate for “fertility awareness-based methods of family planning”; and recommend referrals to faith-based organizations in the case of “needs outside the scope of family planning” —such as abortion, which such faith-based organizations presumably oppose. The inconsistency between the 2018 and 2019 guidance is worth noting; under the previous administrations, grant expectations remained did not change from year to year.

In 2018, the guidelines’ Program Description laid out how an applicant could be comprised of either a single provider or a group of providers that togetherprovided a broad range of family planning methods —which did not include birth control. The following year, the Title X guidelines maintained the partnership clause but mandated that at least one of the partnering organizations has to provide hormonal contraceptives. At first glance, the designation of birth control as essential is a welcome change from the 2018 guidelines. However, the 2019 guidance document also claims abstinence-only education is a form of family planning —and its detailed directions on partnerships pave the way for anti-birth control groups to take funding from the under-resourced family planning program.

Download the PDF below for a side by side chart comparison of the 2018 Title X grant process and scoring guidelines, and the 2019 issued guidelines.

Title X: Obama Era Vs. 2019 Grant Announcements

A comparison of Obama Administration’s last-issued Title X guidelines —consistent between 2016 and 2017—to the second set of guidelines produced by the Trump Administration in 2019 highlights the divergent approaches to reproductive health care. Trump’s HHS appears determined to undermine what remains the only federal family planning program by attacking the essence of the program.

In 2016 and 2017, the number of patients served —especially low-income patients, who receive priority under Title X —and how badly family planning services were needed in the proposed area of the project, were treated as two separate application categories worth a cumulative 30 points. In 2019, these criteria that represent the mission of the Title X program have been consolidated into a singular category worth just 15 points.

And for the second year in a row, final grant-award decisions are made by the Deputy Assistant for Population Affairs —a political appointee —rather than the Regional Health Administrators, who had done so for decades to maintain the integrity of the Title X funding process.

The influence of anti-abortion crusaders at HHS remains clear, as the 2019 grant announcement comes on the heels of the proposed Domestic Gag Rule, which would mandate Title X recipients to create a physical separation of family planning services from abortion services —creating a financial burden for these clinics and impeding on abortion access for many women in one fell swoop. Hints of this rule change (which is currently held up in court) are evident with the category referring to the adequacy of facilities and staff being restored to 20 points in 2019 —after it was docked by 50 percent in 2018—likely to ensure project recipientscan adhere to the proposed Domestic Gag Rule guidelines.

Additionally, under Obama, a Title X applicant could designate subawards to execute additional family planning services that it would not provide. In 2019, the guidelines’ Program Description laidout extremely clearly how an applicant could be comprised of either a single provider or a group of providers that togetherprovided a broad range of family planning methods —one of which has to provide hormonal contraceptives. While birth control shouldbe designated as essential, the same guidance document claims abstinence-only education is a form of family planning —and its detailed directions on partnerships pave the way for anti-birth control groups to take funding from the under-resourced family planning program.

Download the PDF below for a side by side comparison of the 2016/2017 Title X grant process and scoring guidelines, and the 2019 issued guidelines.

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