Public comments for: Disclosure by Pregnancy Services Centers

Comments

Comment:
My name is Sara Birnel Henderson, and I am a health center escort for Planned Parenthood of New York City health centers in Manhattan and Brooklyn, and I have firsthand experience seeing the practices and tactics that pregnancy service centers, or crisis pregnancy centers (CPCs), use to deceive potential patients. Local Law 17 of 2011 provides important regulations for pregnancy service centers. I'm happy to see the proposed rules regarding this law, and I recommend that these rules be very explicit and specific to encourage compliance and that they include adequate enforcement mechanisms. CPCs and their deceptive practices are a major reason why volunteers like myself are needed to help patients safely enter health centers that provide legitimate reproductive health care services, including abortion. One way that CPCs mislead people is by locating their centers near, or even in the same building as, legitimate reproductive health care providers. For example, there is a CPC located in the same building as the Planned Parenthood of NYC health center in Brooklyn. From what I witness during escort shifts, I never get the sense that CPCs want to help women. They use deceptive and harmful tactics to mislead patients and keep them from accessing the care they are seeking. CPCs provide women with false information about abortion procedures and birth control and even direct patients in the wrong direction of PPNYC’s health centers. I have heard and seen this firsthand. CPCs also include deceptive information on their materials to represent themselves in ways that make patients think they are affiliated with Planned Parenthood. One example of this is that they often include information about abortion, a service they don’t provide, on their websites, which misleads someone seeking an abortion. Once a client arrives under false pretenses, staff then discourage and “counsel” clients not to get the medical care they want and need. These practices can gravely harm women's health, especially if they are coming to the health center for time-sensitive services. I support the proposed rules’ specific requirements for signs and website disclosures; however, it is important that disclosures are clear and comprehensible. The purpose of the law is to make sure any person entering a CPC knows what type of facility they are in, yet the disclosure language is both confusing and lengthy, likely making it ineffective. Pregnant people deserve better this. They deserve medically accurate, safe, accessible, quality health care and information, and they deserve to know if that won’t be provided. In order to simplify and clarify the proposed language, I recommend the oral and written disclosure language simply state: "This facility does not have a licensed medical provider on site to provide or oversee all services." Thank you for the opportunity to testify - please find full comments attached.
Supporting Document:
Agency: DCA
Comment:
Dear Department of Consumer Affairs: My name is Dr. Chris Creatura and I am an Obstetrician and Gynecologist on faculty at Weill-Cornell Medical College. When a woman faces an unplanned pregnancy, she deserves compassionate, scientifically accurate information about all of her options. This is the standard of care I provide my patients, and it should be the standard of care for every pregnant woman in New York City. Unfortunately, this isn’t the case at so-called crisis pregnancy centers (CPCs) which are, in fact, anti-abortion organizations where unlicensed staff pose as legitimate health care providers and use scare tactics and misinformation that interfere with patients’ timely access to care for legal and medically important services. This is dangerous and must be stopped. The proposed rules create important disclosure requirements for CPCs that mislead and deceive women. However, I am concerned that the required language does not go nearly far enough in protecting consumers and providing the accurate and honest information New Yorkers deserve. As a healthcare professional, I know firsthand how important it is to make sure clients receive concise, easy to understand materials in order to make informed decisions, and that center staff clearly communicate all important health messages. Our patients' safety and health depends on it. Under the Council legislation, centers that appear to be licensed medical facilities also have a responsibility to clearly inform consumers of their services. This requires taking into account language and literacy levels so that no one is unfairly subjected to the misinformation and delay in care CPCs provide. As it stands, the length and content of the proposed disclosure would likely confuse a majority of the consumers that have mistakenly entered CPCs looking for comprehensive reproductive health care. For this reason, I recommend the oral and written disclosure language be simplified, to state: "This facility does not have a licensed medical provider on site to provide or oversee all services." It is also critical that the confidentiality of consumers' personal health information be protected and that CPCs are held liable for any violation of the law. In order to assess whether disclosure and confidentiality requirements are consistently and effectively enforced, I recommend that the Department of Consumer Affairs enact clear measures for accountability and public reporting. Every pregnant person should receive timely medical attention from a licensed medical professional. As a physician, I can assure you that everyone knows someone who has needed an abortion. None of us would want to be deceived by someone posing as a health care provider and interfering with a private medical decision. This legislation has the potential to improve health care and protect the welfare of all women and their families. Thank you for the opportunity to testify and submit comments on this important issue.
Agency: DCA
Comment:
I am submitting the comment below regarding the proposed rule on Pregnancy Service Centers, Subchapter 17 to Chapter 5 of Title 20 of the Administrative Code of he City of New York. I understand that the Department of Consumer Affairs is holding a hearing on January 11th on the proposed rule and i am asking you to consider my comment as part of the review process. First, thank you for the opportunity to comment on the proposed rule for Local Law 17. As a long time New York City resident, I appreciate the Department of Consumer Affair's efforts to implement this important law consistent with the purpose of accurately informing potential health care consumers of the services offered by these centers. In that regard, one of the primary purposes of this law is to inform potential patients of the narrow nature of the services offered at these centers and specifically what is NOT offered. It is vitally important that the message be crystal clear and concise. I think that requiring the posting of a specifically worded sign with explicit signage requirements promotes these goals. However, I think that the proposed language for the sign is unduly lengthy and confusing and can be easily simplified. I support the proposed language suggested by Planned Parenthood of the City of New York which is the following: "This facility does not have a licensed medical provider on site to provide or oversee all services." Again thank you for the opportunity to submit my comment and for your efforts to implement this important law. Sincerely, Tracy Sivitz
Agency: DCA