July 29, 2016
Department of State Health Services
A Woman’s Right to Know Information Material
Re: Comments on WRTK informational material, draft posted June 28, 2016
We appreciate the opportunity offered by the Department of State Health Services (DSHS) to provide comments on the proposed revision of the A Woman’s Right to Know (WRTK) booklet. The 49,000 physicians and medical student members of the Texas Medical Association have a professional commitment to honoring a patient’s right to make informed personal health decisions, and thus we have a substantial interest in the quality of the mandated WRTK information booklet in Texas.
We have shared our concerns with DSHSi numerous times on terminology and information in WRTK that are neither accurate nor current. Unfortunately, the proposed revisions to the pamphlet do not address these concerns. The department’s website states that revisions will be “guided by peer-reviewed scientific and medical literature, resources from medical organizations, and government health sources.” However, we do not believe any of the proposed revisions reflect that statement. We continue to be concerned with the biased terms and inferences throughout the pamphlet, on almost every page. This includes:
The use of non-neutral terms such as “your baby” (pp, 4-9), “the baby,” and, “unborn child” instead of referring to the fetus and fetal development — the terms recognized to describe this period of human development:
- Details about the fetal development period that are meant to evoke a response and are not used in other DSHS materials on pregnancy;
- Weighted information on abortion risks for which there is questionable evidence as well as great detail on medical procedures associated with abortion (pp. 16-19) without noting that the risks associated with the procedures or that deaths from abortion are rare and that no deaths have been reported in Texas in years; and
- Highlighting a limited number of social and medical resources available for women during pregnancy and childbirth without noting that not all women will be eligible (pp. 3, 13).
While the booklet devotes much attention to abortion risks, it lacks information on current topics such as the risks of maternal morbidity and mortality — most notable as the Texas Legislature has directed DSHS to support study in this area (p. 20). It also has no information about the studies and evidence on the social and economic impact on families with an unplanned pregnancy and late pregnancy care.
There is no sourcing for the information provided on the risks identified with an abortion (mental health, breast cancer, or future infertility, pp. 10-11). The few sources provided in the booklet are incompletely presented and not useful. The use of the CV Bellieni report (p. 4) as a source of information on fetal pain is a particular concern. This report is not recognized by major medical organizations or the scientific community as the definitive report on the perception of pain by a fetus.
Extensive study and research tells us that for patients to make informed health decisions they must have factual information on benefits and risks — provided in neutral, qualitative terms and wording that align with the patient’s health values and knowledge. This is not a one-size-fits-all approach, and the proposed revisions to the WRTK do not measure up to the needs of a woman seeking information on a medical procedure ensured under state and federal law.
Medical professionals and the general public look to our locally, state-, and federally funded agencies to maintain the highest standards in providing current, unbiased, correct information on topics and issues of importance to our residents. We are disappointed that DSHS has not taken even minimal effort to obtain public input before updating the WRTK information. We recognize that there are many with firm convictions that the WRTK is an essential tool in influencing the medical decision-making of women seeking a legal procedure. However, physicians alone are entrusted with ensuring a woman can make an informed decision.
We welcome an opportunity to work with you directly to contribute to the much-needed revisions of this informational booklet.
Shanna M. Combs, MD, FACOG
Chair, Committee on Reproductive, Women’s and Perinatal Health
Texas Medical Association