Screening & Prevention
OPA Issues Revised Title X Guidelines
On January 11, 2001 the Office of Population Affairs issued revised Program Guidelines for Project Grants for Family Planning Services. These guidelines were last revised in 1981. A copy of the guidelines, as well as an appendix including applicable laws and regulations, and regional office staff has been posted on the OPA website at www.hhs.gov/opa/. Copies have been mailed to regional offices and should be available within a month through the OPA Clearinghouse.
OPA's interpretive guidance did not require clearance by other agencies within the government or publication in the Federal Register because it does not establish new policy. The guidelines have been updated to reflect changes in clinical practice, clarify existing policies, give providers more flexibility, and incorporate changes to regulations, laws, and policy guidance. The changes are effective immediately. Any questions should be directed to Sue Moskosky at the Office of Family Planning. Her email is smoskosky@osophs.dhhs.gov. Please cc Evelyn Kappeler at ekappeler@osophs.dhhs.gov and Mimi Kanda at MKanda@osophs.dhhs.gov.
According to the Office of Population Affairs, some of the key revisions/clarifications included in the guidelines are as follows:
Clarifications to Administration and Management Section:
- Charges to minors must be based on the income of minor.
- The sliding fee scale runs between 101-250 percent of the federal poverty level. No additional justification is required for a schedule of discounts above 200 percent of the federal poverty level.
- Donations are permissible but cannot be a prerequisite for the provision of services.
- Overall responsibility for review and approval of information and education materials rests with the grantee, but may be delegated to the contract agency.
- "Recommended" and "Related" Services Combined into One Section: The three sections (required, recommended, and related) under the 1981 guidelines have been collapsed into two sections. "Required" services are those stipulated in law or regulation or that are essential to the provision of high quality family planning services. The sections formerly labeled "recommended" and "related" services have been combined into one section entitled "related." Related services are those intended to promote the general reproductive health of patients, including special gynecologic procedures, genetic screening, etc. but which are not required by law or regulation. The reference to the use of Title X funds for pre-natal care has been deleted.
- History, Physical Assessment, and Laboratory Tests (Section 8.3) - The 1981 guidelines required both initial and annual physical exams, including pap tests, pelvic and breast exams be provided to all clients requesting any prescription method of contraception. The revised guidelines require that all physical and lab tests requirements stipulated in the prescribing information for specific methods of contraception must be followed. For example, the FDA labeling for oral contraceptives and Depo allows deferral of physical exam and lab tests until after the initiation of the method if requested by the client and if judged appropriate by the clinician. The guidelines specify that deferrals of physical exams should not go beyond three months after the initial visit, and should in no case can they go beyond six months. Deferrals must be documented in the patient's record.
- Reference to Emergency Contraception Added to Section on "Reversible Contraception" (Section 8.4) The revised guidelines have been updated to include references to emergency contraception. The "reversible contraception" section notes that "certain oral contraceptive regimens have been found by the Federal Food and Drug Administration to be safe and effective for use as postcoital emergency contraception when initiated within 72 hours after unprotected intercourse." This language mirrors an earlier program guidance issued by OPA.
- Sexually Transmitted Diseases: The 1981 guidelines have been changed to move STD services from the "required" services to "related," because they are not specifically required by statute. This was not intended to downgrade their importance, but to reflect the specific legal requirements. However, STD testing is considered "required" if the prescribing information for a method
