Memorandum of Support: The Comprehensive Contraception Coverage Act (CCCA)
A. 1378 (Cahill)/ S. 3668 (Bonacic)
This legislation would amend various provisions of law to require health insurance policies to provide coverage of all FDA-approved contraceptive drugs, devices and products, as well as voluntary sterilization procedures, contraceptive education and counseling and related follow-up services, and would prohibit a health insurance policy from imposing cost-sharing or other restrictions or delays with respect to this coverage. ACOG District II supports access to comprehensive contraception care and contraceptive methods and therefore, the American Congress of Obstetricians and Gynecologists (ACOG), District II supports this legislation.
ACOG District II is committed to encouraging and upholding policies that ensure robust access to contraception care and contraceptive methods.1 Despite the ubiquity of contraceptive use among sexually active women, multiple barriers prevent women from obtaining contraceptives or from using them effectively and consistently.2 The CCCA is designed to address these barriers in order to promote consistent and effective use of contraception and to prevent unintended pregnancy.
In accordance with the preventive services requirements of the Affordable Care Act (ACA), the CCCA would require New York State insurers to cover at least one method of contraception from each of the 18 distinct categories recognized by FDA with no copayment. Insurers would also be required to cover each of the differing formulations without cost-sharing due to some contraceptive categories including methods with differing therapeutic and pharmaceutical makeups. The CCCA would also require coverage of contraceptives prescribed to men and male sterilization without cost-sharing, would allow patients to access Emergency Contraception (EC) at a pharmacy with a non-patient specific prescription in order to have it covered by insurance, and would provide coverage for the dispensing of 12 months of contraceptives at one time.
Contraception is vital to women’s health and has a myriad of public health benefits, including: maternal and child health benefits due to pregnancy spacing, a reduction in unintended pregnancies and abortion rates, decreased risk of endometrial and ovarian cancers, reduced risk of gynecologic disorders, decreased bleeding and pain during menstruation, economic self-sufficiency for women, and female engagement in the workforce.3
There is a tremendous need to ensure women have access to the contraceptive method that best meets their reproductive needs. Reducing adolescent and unplanned pregnancies are key goals of New York State as identified in its Prevention Agenda 2012-2018.4 Unintended pregnancy and abortion rates are higher in the United States than in most other developed countries5 and New York State has among the highest rates of unintended pregnancy in the nation at 55%.6
There are steep costs associated with unintended pregnancy. Women and their families may struggle with the challenge of an unintended pregnancy for medical, ethical, social, legal and financial reasons.7 Also, the broader financial ramifications of unintended pregnancy are quite sobering. In 2010, 70.2% of unplanned births in New York were publicly funded, compared with 68% nationally.8 In New York in 2010, the federal and state governments spent $1.5 billion on unintended pregnancies; of this, $937.7 million was paid by the federal government and $601.1 million was paid by the state.9
Unfortunately, financial barriers can significantly impact women’s access to effective contraception methods. One in four women in the United States who obtain contraceptive services seek these services at publicly funded family planning clinics.10 Impediments to contraceptive access are not only experienced by those seeking such services; in the absence of ACA protections, women with private insurance may contend with high out-of-pocket costs, deductibles and copayments11 and inability to meet their financial portion particularly for long acting reversible contraceptives (LARCs) such as IUDs. Additional insurance barriers include plan restrictions that limit women from receiving more than a single month’s supply of contraception at a time.12
The CCCA is a practical approach to addressing barriers to contraceptive access and to reducing New York’s rate of unintended pregnancy. For all of these reasons, ACOG District II encourages the legislature to support this legislation.
4 New York State Department of Health. New York State Prevention Agenda 2013-2018: Priorities, Focus Areas, Goals and Objectives. Revised March 2015. https://www.health.ny.gov/prevention/prevention_agenda/2013-2017/tracking_indicators.htm
5 The American College of Obstetricians and Gynecologists, Committee Opinion Number 615. January 2015. http://www.acog.org/Resources-And-Publications/Committee-Opinions/Committee-on-Health-Care-for-UnderservedWomen/Access-to-Contraception
6 Kost K, Unintended pregnancy Rates at the State Level” Estimates for 2010 and Trends Since 2002, New York: Guttmacher Institute, 2015. https://www.guttmacher.org/report/unintended-pregnancy-rates-state-level-estimates-2010-and-trends2002
7 The American College of Obstetricians and Gynecologists, Committee Opinion Number 615. January 2015. http://www.acog.org/Resources-And-Publications/Committee-Opinions/Committee-on-Health-Care-for-UnderservedWomen/Access-to-Contraception
8 Sonfield A and Kost K, Public Costs from Unintended Pregnancies and the Role of Public Insurance Programs in Paying for Pregnancy-Related Care: National and State Estimates for 2010, New York: Guttmacher Institute, 2015, https://www.guttmacher.org/report/public-costs-unintended-pregnancies-and-role-public-insurance-programspaying-pregnancy
10 The American College of Obstetricians and Gynecologists, Committee Opinion Number 615. January 2015. http://www.acog.org/Resources-And-Publications/Committee-Opinions/Committee-on-Health-Care-for-UnderservedWomen/Access-to-Contraception