From 2017 to 2018, Florida Pregnancy Care Network reported distributing funds to 56 organizations: three Catholic charities, six churches of a variety of Christian faiths offering pregnancy resources and adoption counseling, seven organizations provide housing to pregnant people without housing – five of which are religiously affiliated – and 40 anti-abortion pregnancy centers.
Contracts between DOH and FPCN present a number of issues, including exorbitant reimbursement rates for the quality of services provided by subcontractors, lack of public data on the number of people served, self-monitoring by subcontractors, and a total lack of wellness services.[1] Additionally, an analysis of materials directly distributed by subcontractors found innumerable instances of the subcontractors spreading disinformation and incorrect medical information, as well as proselytizing to individuals seeking services.
Current Program Requirements
DOH contracts with FPCN for funding distribution, requiring the network to provide services for the Florida Pregnancy Support Services Program. The program objective is to provide “pregnancy support and women wellness services through subcontracted providers… by promoting and encouraging childbirth,” according to a contract signed on June 30, 2017 for services rendered July 1, 2017 to June 30, 2018 (2017-18 contract) . That contract has now been extended to June 2021.[2] The network attempts to achieve this objective by subcontracting with a minimum of 45 Florida anti-abortion pregnancy centers. The services subcontractors are allowed to provide are limited. Subcontractors providing services are required to “solely promote and support childbirth.” Services cannot “include religious content.”[3]
When a client enters a center funded through this program, the primary service received is “pregnancy counseling.” If a person entering a center thinks they are pregnant a pregnancy test is done. If the pregnancy test is negative, the subcontractor is to perform “lifestyle counseling.” The contract does not explain or detail the standards or requirements of lifestyle counseling. Clients with a positive pregnancy tests are to receive:
- Counseling with the goal of childbirth
- Postpartum counseling, including a plan for the client on goals for having and not having children. “This includes baby spacing and management of pregnancy risk factors such as diabetes, high blood pressure, and obesity.”
If a client enters a subcontractor facility with a family member or partner, the family or partner must also receive counseling with a goal of childbirth. Additionally, subcontractors are not required to provide education classes but are to ensure any education classes that are provided include childbirth education, parenting education, and personal finance management services.
The contract requires creation and promotion of OptionLine, a hotline and texting campaign promoting the program. The network is required to ensure the call center is staffed at all times to speak to those “facing unplanned pregnancies and other related concerns.” OptionLine operators consult with and direct callers to a network subcontractor. Numerous details must be reported to DOH for quality assurance. Despite the reporting required, the state does not have a target number of callers or visits for the network to hit.
Reimbursement Rates
DOH reimburses Florida Pregnancy Care Network for direct client services provided by its subcontractors. According to a contract signed June 30, 2017, “direct client services” includes counseling, referrals, and classes and authorized services until June 30, 2018. DOH renewed the contract three times, extending the expiration date of the contract to 2021.[4] Similarly, a contract signed in 2013 (2013-14 contract), had two amendments extending the expiration date.[5] A 2015 amendment to the 2013-14 contract set subcontractor reimbursement rates to the current rate of $50 an hour for face-to-face direct client services, in addition to $1/minute of counseling. By signing the mentioned amendments in replace of entering new contracts, DOH is able to manipulate reimbursement rates granted to Florida Pregnancy Care Network without requiring added oversight or reporting.
Reimbursement rates for counseling services provided by the program’s anti-abortion pregnancy centers are disproportionately higher than state Medicaid reimbursements for many actual health care services. Medicaid reimbursed providers are subject to more oversight, requirements, and licensures than detailed required by subcontractors in the FPCN syndicate. For example in 2017, the state authorized a reimbursement rate of $31.04 per visit for a home health visiting Registered Nurse. A Registered Nurse is required to apply for a license prior to practicing. In order to apply, an applicant must meet specific qualifications, including graduation from a Florida approved or accredited nursing education program. Applying for licensure requires an application fee of $110. Despite the high costs, training, and qualifications needed to be a Registered Nurse in the state of Florida, the state approved Medicaid reimbursement rates are half of what the state reimburses staff at anti-abortion pregnancy centers in the Florida Pregnancy Support Services Program. In contrast, the contract between Florida Pregnancy Care Network and DOH state only vagaries in terms of required staff requirements:
“Professional qualifications: Ensure staff members affiliated with this program have the education, experience and training necessary to successfully carry out their duties. This includes any professional licensure or certification which may be required by law.”
The state reimburses staff at anti-abortion pregnancy centers in the Florida Pregnancy Services Program double the state approved Medicaid reimbursement rates for Registered Nurses in Florida, despite the high costs, training and qualifications needed to be an RN in Florida.
Subcontractor Self-Monitoring
A continued problem with Florida Pregnancy Support Services Program is the lack of adequate monitoring of subcontractors. The program largely allows self-monitoring, including a subcontractor’s own medical provider approving the medical information presented to patients. All concerns, from lack of critical wellness services provided to religious coercion, are therefore left to be assessed by the subcontractors themselves. Moreover, Florida does not require the subcontractors in this program to serve a minimum number of patients or to provide a minimum level of services.[6]
Lack of Critical Wellness Services
The network’s 2017-18 contract requires it to create a wellness program offering “high blood pressure screenings, flu/tetanus vaccines, smoking cessations services, pap smear, and sexually transmitted infection testing.” These services, which are provided by wellness program subcontractors, are mandatory, but the FPCN is only required to subcontract with two wellness centers; one wellness center directly providing services, and an additional wellness center able to provide vouchers for services at another facility.
As of May 2018, 13 of 100 anti-abortion crisis pregnancy sites provided STI testing. Most wellness services appear to be offered to clients through referrals. A website promoting the program allows visitors to search for providers in their area. By using the “wellness” facility search on the website, zero subcontractors appear to offer wellness services, but instead offer “wellness referrals.” These numbers raise the concerning question of what the 68+ other sites were doing instead of providing essential health services.
False and Deceptive Medical Information
An analysis of public information and volunteer materials provided by network subcontractors showed that they are attempting to sway clients with deceptive information. Information on the unsafe and unproven abortion pill reversal technique is often mentioned, in addition to false claims that abortion and birth control can cause depression, future infertility, breast cancer, and suicidal thoughts. For example, Verity Pregnancy and Medical Resource Center (Lee County) and A Woman’s Answer Medical Center (Alachua County), both include deceptive medical information on their websites. Verity claims the risk of breast cancer after an abortion increases by fifty percent, whereas the American Cancer Society states, that abortion does not raise the risk “of breast cancer or any other type of cancer.” A Woman’s Answers Medical Center in Gainesville, Florida, claims on their website that birth control leads to a risk of “[c]ervical and breast cancer.” However, studies show women are not at higher risk for either cancer after taking birth control.
Grace House is an anti-abortion pregnancy center that contracts with FPCN and has three locations in Volusia County. The Grace House website dedicates an entire webpage to those “[c]onsidering [a]bortion.” The webpage lists “snippets” of abortion-related information and requests the webpage viewer to “visit the [Grace House] center for more information.” These snippets appear to be deliberately misleading and intended to encourage a pregnant person viewing the page to schedule an appointment with Grace House. For instance, a section details a “partial birth abortion” as “a procedure in which the life of the fetus is terminated after having been extracted…” trailing off without finishing the sentence. “Partial-birth” is not a medical procedure at all, but a political term coined by the anti-abortion movement in 1995 to describe a standard dilation and evacuation abortion.
The Next STEPP Center in St. Petersburg incorrectly claims “you can only become pregnant on certain days of the month,” as a way to convince site visitors they should not obtain the emergency contraceptive (EC). Additionally contrary to the opinion of The American College of Obstetricians and Gynecologists, Next STEPP promotes the common claim anti-abortion leaders promote that EC is an abortifacient, a drug inducing an abortion. Next STEPP states taking EC “after fertilization has taken place may prevent the newly formed life from settling into the uterus and continuing to grow, which some consider a form of early abortion.” This is false. Studies show EC prevents ovulation. Multiple brands of EC are on the market, including Plan B®. By preventing ovulation, the medication prevents “an egg’s release until sperm can no longer fertilize it.”[7]
Widespread Use of Abortion Reversal Rhetoric
Medication abortion was approved up to ten weeks of pregnancy by the United States Food and Drug Administration (FDA) in 2000. The FDA-approved treatment includes two drugs taken orally – the standard protocol consists of mifepristone and misoprostol. Mifepristone is taken orally followed by misoprostol taken 24 to 48 hours later; when these two drugs are taken together, a medication abortion terminates the pregnancy in 96% of cases.
Research does not support claims that a medical abortion can be reversed. Dr. George Delgado advanced an experimental treatment claiming to “reverse” abortion by foregoing the second medication abortion drug, misoprostol, and instead administering a regimen of the hormone progesterone.[8] There is no specific protocol for the progesterone treatment, beyond a large amount of progesterone administered by injection, orally or vaginally, for an unspecified length of time, and sometimes throughout the remainder of the pregnancy.[9] Mifepristone is used to block progesterone formation causing the pregnancy to detach from the uterine wall, so the unproven hypothesis of this experimental treatment is that progesterone can counteract the effects of mifepristone.[10] The FDA has not approved this untested and unproven so-called abortion pill reversal treatment.
Dr. Delgado’s hypothesis is based on flawed experiments, including his 2012 and 2018 case studies.[11] In 2019, researchers from the University of California, Davis had to halt a study into the efficacy of progesterone in preventing an abortion once mifepristone has been taken due to safety concerns after three patients experienced vaginal bleeding. The researchers concluded:
We could not estimate the efficacy of progesterone for mifepristone antagonization due to safety concerns when mifepristone is administered without subsequent prostaglandin analogue treatment. Patients in early pregnancy who use only mifepristone may be at high risk of significant hemorrhage.
Numerous anti-abortion pregnancy centers promote abortion pill reversal, despite the risk of harm to patients. A Woman’s Choice in Lakeland, Florida, claims that a medical abortion can be reversed but it is a “time-sensitive medical protocol.” Pregnancy Help & Information Center (PHI Center) of Tallahassee highlights abortion pill reversal on the Frequently Asked Questions section of its webpage. PHI Center claims abortion pill reversal has a “64-68% success rate” and directs website visitors to abortionpillreversal.com – a website managed by Abortion Pill Rescue[12] – for more information. Guiding Star Tampa in Lutz pressures a website visitor to call the hotline run by the organization and claims their “medical professionals” will guide callers towards reversing the effects of the abortion pill.” In addition to the numerous anti-abortion pregnancy centers promoting the abortion pill reversal hypothesis, Florida Pregnancy Care Network, through its own website, promotes Abortion Pill Rescue via a hyperlink attached to the words “Emergency Pregnancy Services.”
Religious Coercion
Florida Pregnancy Care Network’s contract with DOH prohibits religious coercion: “Ensure that all services provided with funds from this contract are provided in a manner that is non-coercive 
and does not include religious content.” However, the network spent “several years” of state funding on educational materials which “create openings for counselors to share Christ” — which can be billed as “counseling” to the state. The counseling budget included materials from Earn While You Learn — a company that sells religious pregnancy and parental learning materials. Earn While You Learn is a religious curriculum allowing anti-abortion pregnancy center counselors “to share Christ.” Earn While You Learn provides classes and material support to women to “become a successful mother.”
Anti-abortion pregnancy centers subcontracted by FPCN require volunteers to complete applications. These applications ask in-depth questions of a potential volunteer, such as the applicant’s view of abortion, if they know someone who has had an abortion, and what church they belong to. Many applications even require applicants to provide referrals from the church’s pastor.
Grace House, with three centers in Volusia County, describes its organizational structure as a “501(c)3 Christian mission,” referring to Grace House’s nonprofit tax filing status. A volunteer brochure from Grace House shows applicants are able to choose how they assist the organization. Volunteer applicants have a choice of client advocates, volunteers for the ultrasound program, or counselors. According to a brochure from Grace House, client advocates share the gospel and pray with clients, while volunteers for the ultrasound program are required to have various medical degrees. This seems to indicate volunteers provide ultrasounds and testing. Finally, volunteers can be counselors, leading “abortion recovery” counseling, and facilitating an 11-week Bible study once or more a year.
Grace House does not recommend, provide or refer single women for contraceptives. Married women seeking this information are urged to seek counsel, along with their husbands, from their pastor and physicians. Additionally, Grace House requires “a commitment to the sanctity of human life, even in the hard case of rape, incest and suspected fetal deformity.”
Grace House is not the only FPCN subcontractor to include this information in application materials for a volunteer; A Women’s Pregnancy Center (Leon County)[13] and Bay Area Pregnancy Center (four centers in Pinellas County),[14] for example, also require volunteers to be of the Christian faith.
Wasteful Program Budget
Each anti-abortion pregnancy center’s contract with Florida Pregnancy Care Network is administered by DOH. Over the years, DOH has approved seemingly wasteful budget line items. An example is the DOH and Florida Pregnancy Care Network 2013-14 contract. Through numerous amendments, the contract term extended to June 30, 2017. In a September 2015 amendment, DOH approved $508,000 for educational materials. This was increased by $50,000 to $558,000 in April 2016. However, three months later in July 2016, the requirement that the network provide sample curricula for subcontractors was deleted from the contract, leaving local centers to provide education services without DOH knowing the content of those services.
Education Materials
DOH replaced the curricula requirement in July 2016 with a requirement that ten subcontractors provide employability training to clients through the “Win at Work” software program. Local centers funded by the program had thirty days to purchase the program from the contract’s execution date. The program was given $27,500 for the employability training. After these required expenditures, the requirement was cut a year later and is not included in the 2017 contract.
OptionLine
As mentioned above, OptionLine, a toll-free hotline – 1-866-673-HOPE – and texting bank is defined in the contract as a call center “for women to obtain the location and contact information for a pregnancy center in their area.” The network and DOH currently budget OptionLine at $40,000, but the budgeted amount went to its highest level of $50,000 in 2016.[15] The $40,000 budget amount does not include a salary line item or details into the OptionLine, making it unclear who operates the hotline. Instead, the budget allocates $4.25 per call made to the hotline, and the texting bank costs the network $25 per month.
OptionLine appears to be another tool to coerce pregnant people away from accessing abortion services. A call was placed to OptionLine on November 15, 2020. The caller told the hotline operator that they thought they were pregnant and wanted to learn their options. The operator took the caller’s zip code and directed the caller to North Miami Pregnancy Help Center (Dade County). Overall, the call lasted two minutes. Based on the contractual budget, this two-minute call cost the state of Florida $4.25 or about $2.13 per minute. An additional web search shows the North Miami Pregnancy Help Center is actually Pregnancy Help Medical Clinics, with four locations in South Florida, offering free pregnancy testing, ultrasounds, community resources, STD/STI information, and “information on your options.” Pregnancy Help Medical Clinics does not provide medical services. Instead, their website provides deceptive and misinformation about abortion services designed to scare pregnant people away from obtaining care. The OptionLine is used as another way to coerce pregnant people by directing them to anti-abortion pregnancy centers.
Contract Management
Florida Pregnancy Care Network is in charge of contract management to ensure the anti-abortion pregnancy centers are compliant with program requirements. Since the 2013-14 contract, management fees budgeted for the network have steadily increased while its oversight requirements have decreased.[16] DOH reimburses the network $500 per subcontractor per month for project management. The contract requires a minimum of 45 subcontractors, meaning the contract management minimum is $270,000 per year. There is no explanation within the signed contracts between DOH and the Florida Pregnancy Care Network for how the $500 is used and no clear reporting requirement connected with receipt of the $500 per subcontractor per month. In a contract signed in 2009 (2009-10 contract), DOH reimbursed at $416.50 per subcontractor per month, decreasing to $380 per subcontractor per month in the 2013-14 contract, before increasing to the current $500 per subcontractor per month.
Lax Monitoring and Oversight
Monitoring and oversight requirements of Florida Pregnancy Support Services Program by DOH have lessened or dropped altogether as Florida Pregnancy Care Network’s contractual amount increased thus providing less accountability for how taxpayer dollars are being used. In a 2011 amendment to the 2009-10 contract, DOH added a requirement that the network submit a monthly narrative of its executive director’s activity. This was dropped in a 2015 amendment to the 2013-14 contract and never reinstated. In the 2009-2010 contract, DOH required immediate notification of subcontractor termination. This requirement was later extended to notify the agency within 30 days. In a 2011 amendment, onsite monitoring of all subcontractors was required annually, but in 2013 this was changed to “a monitoring” with no time frame required. In the 2017-18 contract, DOH required either an onsite visit, or a “desk review.” An explanation for what is required of a desk review was not given. In a June 2018 amendment, the requirement to monitor subcontractors every other year was removed, leaving only the mandate to monitor subcontractors through an undefined desk review, without a timeframe in which to do so.
[1] Florida Pregnancy Support Services Program, Contract COHN6, State of Florida Department of Health and Florida Pregnancy Care Network, Inc. (Jun. 30, 2017), available at https://beta.documentcloud.org/documents/7208161-CN-640000-COHN6; Florida Pregnancy Support Services Program, Contract COHD2, State of Florida Department of Health and Florida Pregnancy Care Network, Inc. (Jul. 3, 2013), available at https://beta.documentcloud.org/documents/20412915-cn-640000-cohd2; Florida Pregnancy Support Services Program, Contract #COH5P, State of Florida Department of Health and Florida Pregnancy Care Network, Inc. (Jul. 16, 2009), available at https://beta.documentcloud.org/documents/20412911-cn-640000-coh5p.
[2] Florida Pregnancy Support Services Program, Contract COHN6, State of Florida Department of Health and Florida Pregnancy Care Network, Inc., 8 (Jun. 30, 2017), available at https://beta.documentcloud.org/documents/7208161-CN-640000-COHN6. Florida Pregnancy Care Network and State of Florida Department of Health, Contract COHN6: Renewal #1, State of Florida Department of Health (Jun. 4, 2018), available at https://beta.documentcloud.org/documents/20412975-cn-640000-cohn6-r1; Florida Pregnancy Care Network and State of Florida Department of Health, Contract COHN6: Renewal #2, State of Florida Department of Health (Jun. 28, 2019), available at https://beta.documentcloud.org/documents/20412976-cn-640000-cohn6-renewal2-2019; Division of Community Health Promotion, Contract # COHN6: Contract Summary, Division of Community Health Promotion (Jun. 30, 2020), available at https://beta.documentcloud.org/documents/20412974-cn-640000-cohn6-r3a1.
[3] Florida Pregnancy Support Services Program, Contract COHN6, State of Florida Department of Health and Florida Pregnancy Care Network, Inc. (Jun. 30, 2017), available at https://beta.documentcloud.org/documents/7208161-CN-640000-COHN6; Florida Pregnancy Support Services Program, Contract COHD2, State of Florida Department of Health and Florida Pregnancy Care Network, Inc. (Jul. 3, 2013), available at https://beta.documentcloud.org/documents/20412915-cn-640000-cohd2; Florida Pregnancy Support Services Program, Contract #COH5P, State of Florida Department of Health and Florida Pregnancy Care Network, Inc. (Jul. 16, 2009), available at https://beta.documentcloud.org/documents/20412911-cn-640000-coh5p.
[4] Contract Renewal #1, Contract COHN6, State of Florida Department of Health and Florida Pregnancy Care Network, Inc. (Jun. 4, 2018), available at https://beta.documentcloud.org/documents/20412975-cn-640000-cohn6-r1; Contract Renewal #2, Contract COHN6, State of Florida Department of Health and Florida Pregnancy Care Network, Inc. (Jun. 29, 2019), available at https://beta.documentcloud.org/documents/20412976-cn-640000-cohn6-renewal2-2019; Amendment: Contract Summary, Contract COHN6, State of Florida Department of Health and Florida Pregnancy Care Network, Inc. (Aug. 7, 2020), available at https://beta.documentcloud.org/documents/20412974-cn-640000-cohn6-r3a1.
[5] Florida Pregnancy Support Services Program, Contract COHD2, State of Florida Department of Health and Florida Pregnancy Care Network, Inc. (Jul. 3, 2013), available at https://beta.documentcloud.org/documents/20412915-cn-640000-cohd2; Contract Renewal #1, Contract COHD2, State of Florida Department of Health and Florida Pregnancy Care Network, Inc. (Jun. 24, 2014), available at https://beta.documentcloud.org/documents/20413041-cn-640000-cohd2-r1; Contract Renewal #2, Contract COHD2, State of Florida Department of Health and Florida Pregnancy Care Network, Inc. (Apr. 30, 2015), available at https://beta.documentcloud.org/documents/20413040-cn-640000-cohd2-r2; Contract Renewal #3, Contract COHD2, State of Florida Department of Health and Florida Pregnancy Care Network, Inc. (May 4, 2016), available at https://beta.documentcloud.org/documents/20413039-cn-640000-cohd2-r3.
[6] Florida Pregnancy Support Services Program, Contract COHN6, State of Florida Department of Health and Florida Pregnancy Care Network, Inc. (Jun. 30, 2017), available at https://beta.documentcloud.org/documents/7208161-CN-640000-COHN6; Florida Pregnancy Support Services Program, Contract COHD2, State of Florida Department of Health and Florida Pregnancy Care Network, Inc. (Jul. 3, 2013), available at https://beta.documentcloud.org/documents/20412915-cn-640000-cohd2; Florida Pregnancy Support Services Program, Contract #COH5P, State of Florida Department of Health and Florida Pregnancy Care Network, Inc. (Jul. 16, 2009), available at https://beta.documentcloud.org/documents/20412911-cn-640000-coh5p.
[7] Julie Rovner, Morning-After Pills Don’t Cause Abortion, Studies Say, NPR (Feb. 21, 2013), available at https://www.npr.org/sections/health-shots/2013/02/22/172595689/morning-after-pills-dont-cause-abortion-studies-say; Pam Belluck, Abortion Qualms on Morning-After Pill May Be Unfounded, The New York Times (Jun. 5, 2012), available at https://www.nytimes.com/2012/06/06/health/research/morning-after-pills-dont-block-implantation-science-suggests.html?pagewanted=all.
[8] See George Delgado et al., A Case Series Detailing the Successful Reversal of the Effects of Mifepristone Using Progesterone, 33 Issues in Law & Medicine (2018).
[9] Id.
[10] Id.
[11] See Daniel Grossman & Kari White, Abortion “Reversal” – Legislating Without Evidence, 379(16) New England Journal of Medicine 1401-03 (2018).
[12] Abortion Pill Rescue, Home, AbortionPillReversal.com (last accessed Nov. 18, 2020), available at https://www.abortionpillreversal.com/about/our-team. CfA called on the FDA to seize the website domain belonging to Abortion Pill Rescue, among others, due to the websites peddling a potentially dangerous abortion pill reversal. Letter to Dr. Janet Woodcock and Donald Ashley, Referral of Unlawful Prescription of Dangerous Abortion Pill Reversal, Campaign for Accountability (May 20, 2020), available at https://campaignforaccountability.org/wp-content/uploads/2020/05/FDA-Letter_Abortion-Reversal_5_20_2020.pdf.
[13] See Figure 3.
[14] See Figure 1 & 4.
[15] Amendment: Contract Summary, Contract COHN6, State of Florida Department of Health and Florida Pregnancy Care Network, Inc. (Aug. 7, 2020), available at https://beta.documentcloud.org/documents/20412974-cn-640000-cohn6-r3a1; Florida Pregnancy Support Services Program, Amendment #R3A1 Contract COHD2, State of Florida Department of Health and Florida Pregnancy Care Network, Inc., 30 (Jun. 28, 2016), available at https://beta.documentcloud.org/documents/20412898-cn-640000-cohd2-r3a1-4.
[16] Florida Pregnancy Support Services Program, Contract COHD2, State of Florida Department of Health and Florida Pregnancy Care Network, Inc. (Jul. 3, 2013), available at https://beta.documentcloud.org/documents/20412915-cn-640000-cohd2; Florida Pregnancy Support Services Program, Contract COHN6, State of Florida Department of Health and Florida Pregnancy Care Network, Inc. (Jun. 30, 2017), available at https://beta.documentcloud.org/documents/7208161-CN-640000-COHN6.