Americans United for Life has submitted formal comment to the Centers for Medicare & Medicaid Services (CMS) in response to the agency’s Request for Information on “medical aid in dying” (MAID) in the context of Medicare hospice care. AUL’s comments make clear that the federal government must not allow deceptive and euphemistic language when referring to assisted suicide. AUL also points out inadequate oversight, which obscures the serious concerns of patient safety, disability rights, and informed consent failure that are prevalent in the jurisdictions where assisted suicide is legal in the United States.
The Problem with “MAID” or Medical Aid in Dying
Language matters. In the same way abortion is not healthcare, assisted suicide is not “medical aid”. AUL’s comment opens with a direct request to stop using the term “MAID.” The phrase “medical aid in dying” sanitizes a practice that is a physician prescribing a lethal drug dose to end a patient’s life. The American Medical Association has itself rejected the term, noting it is “neither precise nor accurate.” Congress has consistently used the language “assisted suicide, euthanasia, or mercy killing” in federal law, including the Assisted Suicide Funding Restriction Act and the Affordable Care Act’s conscience protections. United States Department of Health and Human Services (HHS) and CMS should follow suit. Killing innocent human beings is wrong, no matter what you call it, and clear language helps the public understand the reality of physician-assisted suicide.
Assisted Suicide is Legal in Only 14 Jurisdictions and Riddled with Failures
Assisted suicide is legal in only fourteen U.S. jurisdictions, twelve states plus the District of Columbia, and Montana through court action. Even in these states, the supposed “safeguards” are failing patients. AUL’s comment documents alarming gaps:
Informed consent is not being protected.
Studies show that 25–50% of patients seeking assisted suicide exhibit signs of depression. This is a condition that can impair the very decision-making capacity the law purports to uphold. Yet in Oregon in 2025, prescribers wrote 637 lethal prescriptions while referring only two patients for psychiatric counseling.
Prescribers often don’t know their patients.
Oregon’s 2025 data shows the median patient-physician relationship in assisted suicide cases was just four weeks, with some as short as zero weeks. This “doctor shopping” makes meaningful diagnosis of underlying psychiatric conditions nearly impossible.
Nobody is present when patients die.
In Oregon in 2025, the prescribing physician was present at the time of ingestion only 23% of the time. In California in 2024, a physician or healthcare worker was present just 48% of the time. There is no requirement that anyone witness the patient’s death or confirm the patient was the one who actually took the drugs.
Lethal drugs are experimental and unregulated.
There is no FDA-approved drug for assisted suicide. Prescribers have been mixing and modifying experimental drug cocktails. These deadly compounds and changing formulations are different year over year without clinical trials, Institutional Review Board oversight, or state guidance on dosing. In 2025, 13% of Oregon prescriptions used a brand-new lethal compound that hadn’t existed in prior years.
Disability Discrimination
Perhaps the most important finding in AUL’s comment is that patients seeking assisted suicide are overwhelmingly not doing so to manage pain. In Oregon and Washington, the top reasons cited were loss of autonomy, diminished ability to engage in enjoyable activities, loss of dignity, and fear of being a burden. Only 37–39% cited inadequate pain control.
These are the very concerns that define life with a serious disability or illness. The National Council on Disability warns that legalizing assisted suicide creates a two-tiered system in which the young and healthy receive suicide prevention treatment while the sick and disabled are offered a lethal drug cocktail instead. That is not compassion. It is discrimination.
Assisted Suicide Increases Overall Suicide Rates
Research is unambiguous: legalizing assisted suicide is associated with a 6.3% increase in overall suicides, not to mention a heart-wrenching 14.5% increase among adults over 65. Far from reducing suffering, the legalization of assisted suicide undermines the very suicide prevention infrastructure that protects the most vulnerable Americans.
AUL’s Requests to CMS
AUL is urging HHS and CMS to take two concrete steps:
- Adopt accurate terminology. Use “assisted suicide” — not “MAID”. Be consistent with federal statute and the AMA’s own guidance.
- Establish federal reporting requirements for hospice programs. Washington’s 2024 data shows providers failed to submit required documentation in hundreds of cases, including 75 missing patient requests, 63 missing attending provider compliance forms, and 65 missing after-death reports. Without federal oversight, abuse goes undetected and violations go unaddressed.
Hospice patients deserve transparency, accountability, and protection, not a system that looks the other way while compliance failures mount and experimental drugs go unchecked.
To read AUL’s full comment, click here.
