July 18, 2016 Department of State Health Services Austin, TX Sent via email to [email protected] To Whom It May Concern: Thank you for the opportunity to comment on the “A Woman’s Right to know” booklet. NARAL Pro­Choice Texas opposes state interference with the doctor­patient relationship in this manner. At the very least, every revision of the booklet should bring us closer to medical and scientific accuracy and away from the shaming misinformation that has dominated the booklet in the past. That is not the case with this revision. Consistent with your admonition that “​Revisions to the booklet will be guided by peer­reviewed scientific and medical literature, resources from professional medical organizations, and government health sources,” We insist that the WRTK booklet be further revised to correct the legion of inaccuracies and slanted language, so that no licensed physician in Texas is forced to disclaim its contents and no patient is forced to experience unnecessary stress or shame as she exercises her constitutionally­protected right to an abortion. In addition to the well documented medical and scientific inaccuracies that have persisted in every edition, the current revision adds more unnecessary, inaccurate, and manipulative information that must be removed. The booklet begins with the proposition that newborn babies can feel pain. This is not controversial or incorrect, but is not relevant to a patient seeking information about abortion, and potentially violates the medical concept of informed consent. The section goes on to explain that the state bans abortion at 20 weeks because of the potential of fetal pain. Not only is this ​not grounded in peer­reviewed medical literature​, but if abortion is banned at 20 weeks, this information does not apply to any patient receiving it in the state for an abortion prior to 20 weeks “probable post­fertilization age.” If the patient qualifies for an exception due to their health or a fetal anomaly, it is patently cruel to force this information upon them, as if they have not already contemplated the options they were facing with their pregnancy. This revision refers to a pregnancy at any stage as “your baby” throughout the pamphlet, even though it disclaims this language by noting that the correct term at certain stages of development is embryo and P.O. Box 684602, Austin TX 78768 ​∙ ​512­462­1661 ​∙ ​[email protected] fetus. In fact researchers have found that more than one third of the statements about embryonic 1
development are inaccurate. The presentation of risk factors of abortion and carrying a pregnancy to term are presented in an inconsistent or biased manner. The health risks of carrying a pregnancy to term far outweigh those of elective abortion. And death is listed at the top of the list of risks, although abortion is one of the safest outpatient procedures and far safer than childbirth, which carries a risk of death 14 times higher than 2
abortion ​. Further, the revision maintains strong links between abortion and breast cancer, a claim that has been 3
thoroughly debunked by major medical organizations. ​ And the emotional effects of abortion are skewed 4
toward the negative, although other studies ​ have concluded most women feel abortion was the right decision for them and negative feelings are more accurately associated with shame and stigma, which, ironically, this booklet appears to perpetuate. As peer­reviewed studies have determined, the so­called research from those such as the repeatedly discredited Vincent Rue is not replicable and this 5
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“post­abortion syndrome” has been debunked ​ and discredited. The resource directory included with the WRTK information conflates licensed medical providers with unlicensed crisis pregnancy centers where little to no health care is offered or available. These facilities should be clearly marked and distinguished from actual health care providers. Additionally, any intimation that a patient could get a sonogram that would meet the other requirements of state law should be removed. We also note that the information for minors should be updated to reflect new legislation further restricting a minor’s access to abortion. Informed consent is a vital component of obtaining an abortion in Texas, but this is not informed consent. It is misinformation intended to coerce patients and perpetuate fear and stigma. This booklet has been influenced and driven by political ideology, not medicine or science, and we believe that patients deserve better than this. The Texas and the Department of State Health Services should not force doctors to lie to their patients. People seeking abortion deserve unbiased, medically accurate information so that they may make decisions about their health and their lives free from coercion, fear or shame. This booklet is a gross interference in the practice of medicine and the doctor­patient relationship and designed to trigger fear and shame. If informed consent is the true purpose of this booklet we respectfully ask that you revise it to be an objective, unbiased resource that does not attempt to unduly influence patients. All information contained therein should be supported by the National Institute of Health and mainstream medical and http://informedconsentproject.com/states/texas/ http://www.ncbi.nlm.nih.gov/pubmed/22270271 3
http://www.cancer.org/cancer/breastcancer/moreinformation/is­abortion­linked­to­breast­cancer 4
http://journals.plos.org/plosone/article?id=10.1371/journal.pone.0128832#sec013 5
http://www.sciencedirect.com/science/article/pii/S027795361000729X 6
http://www.apa.org/pi/women/programs/abortion/ 1
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P.O. Box 684602, Austin TX 78768 ​∙ ​512­462­1661 ​∙ ​[email protected] psychological groups, such as the American Medical Association and the American Psychological Association. P.O. Box 684602, Austin TX 78768 ​∙ ​512­462­1661 ​∙ ​[email protected]