In September, the Department of Health and Human Services (HHS) released its 2018-2022 Strategic Plan to provide new departmental guidance following the 2014 plan from the Obama administration. Upon first glance, it becomes readily apparent that the missions and priorities for HHS under the Trump administration are a significant departure from his predecessor in office. The strategic plan makes clear that this administration is intent on sabotaging the Affordable Care Act’s policies and programs, as well as their lack of interest in serving the interests and needs of all U.S. populations.

#1: No mention of the Affordable Care Act

One of the most notable differences between the Obama administration’s strategic plan and the Trump administration’s is that the current plan makes no reference to the Affordable Care Act (ACA) – a program that has expanded coverage to more than 20 million individuals and provided protections within private health insurance to millions more. Since taking office, the Trump administration has made no secret of its intention to sabotage the ACA. From issuing Executive Orders and decisions that destabilize the individual market, to slashing funding for advertising and enrollment assistance, to producing and disseminating anti-ACA videos on YouTube, the administration has devoted considerable energy to undermining the coverage gains, consumer protections and access to coverage that the Affordable Care Act brought about. It is, nevertheless, concerning that the main agency charged with administering all of the country’s public health insurance programs has written a strategic plan that fails to even reference two core components of our nation’s system of health care coverage – the ACA and the Children’s Health Insurance Program (CHIP) – rather than strategically contemplate ways to build upon their successes and address their shortcomings.

#2: No mention of key populations

What is perhaps even more surprising is the draft plan’s omission of references to certain vulnerable populations within the United States. While the previous Strategic Plan contained many references to supporting and helping LGBTQ individuals access health coverage and obtain meaningful health care services delivered in a culturally competent way, no such language exists in the Trump administration’s plan. For example, the prior strategic plan contained strategies to: “[s]upport research that will increase our understanding of the health and health status of population subgroups such as racial and ethnic minorities, persons with disabilities, the reentry population, rural populations, and lesbian, gay, bisexual, and transgender (LGBT) population.” While the 2018-22 Strategic Plan contains references to other key populations such as children, older adults, individuals with disabilities and individuals with substance use disorders, there are no references to LGBTQ individuals or the LGBTQ population.

Similarly, there are no references to individuals and families with immigration statuses other than refugee status. In contrast, the prior Strategic Plan contained strategies such as to: “[p]rovide online and technological resources to help refugees, other immigrant populations, and service providers connect with mainstream resources to achieve self-sufficiency,” as well as to “[p]rovide supportive services, including health and behavioral health services and supports, and wraparound services like employment, housing, caregiver support, and peer recovery supports, to reduce and eliminate barriers to community living for vulnerable populations, including individuals with disabilities, older adults, the lesbian, gay, bisexual, and transgender (LGBT) community, refugees and immigrants, and individuals at risk for homelessness.

#3: Frequent references to prioritizing the preferences of religious providers and individuals with moral conviction

Another significant departure from the previous Strategic Plan are the frequent references to working with faith-based organizations when carrying out the department’s goals and strategies, as well as administering programs, policies and procedures that do not impose barriers for individuals with religious and moral convictions. Partnering with faith-based organizations when providing outreach and education to individuals regarding access to health coverage is definitely an effective strategy. However, implementing policies that prioritize the beliefs and convictions of religious providers may lead to patients not being able to access the information or services they need to make fully-informed decisions or receive adequate care. For example, one of the listed strategies is to “[t]est new payment models on alternative approaches to end-of-life care that incentivize patient- and family-centered preferences while respecting religious beliefs and moral convictions.”

These key differences demonstrate a staggering departure from the goals and strategies of the previous Strategic Plan. What’s more concerning, though, is that they signify that the health and well-being of low- and middle-income individuals, as well as key vulnerable populations who benefitted from public health initiatives like the ACA, are no longer a priority for the administration.

On Oct. 27, many consumer health advocates and other healthcare stakeholders, including Community Catalyst, submitted comments to HHS expressing these concerns. We hope that HHS will take this feedback into consideration and release a revised version of its plan that addresses the unique needs and issues for all individuals in the United States.