In the United States, prisons are obligated to provide health care to prisoners. Such health care is sometimes called correctional medicine. In women's prisons, correctional medicine includes attention to reproductive health. The number of women incarcerated in the United States has increased greatly over the last few decades, and at a faster rate than the number of incarcerated men. Many of the same factors that increase women's likelihood of incarceration also put them at a higher risk for contracting HIV/AIDS and other sexually transmitted infections, and for having high-risk pregnancies. The majority of incarcerated women are economically disadvantaged and poorly educated, and have not had adequate access to preventive healthcare prior to their imprisonment, such as Pap tests, STI screening, and pregnancy counseling. Legal standards for health care availability Historical precedence Estelle v. Gamble (1976) Estelle v. Gamble obligates prisons to provide for the serious medical needs of their inmates. However, it also requires that an incarcerated person must demonstrate that they had a serious medical need, and that they didn't receive adequate medical care because officials showed "deliberate indifference." Due to the difficulty inherent in proving that a prison official knew about a medical condition, yet failed to respond to it, this standard makes it difficult to hold correctional facilities accountable for their mistakes. Todaro v. Ward (1977) Todaro v. Ward argued that women within a New York prison did not have adequate, constitutional access to healthcare. Since Todaro v. Ward was the first major court case that called into question incarcerated women's actual access to health care, it spurred organizations such as the American Medical Association, American Correctional Association, and the American Public Health Association to start creating standards for health care within prisons. Brown v. Beck (1980) With this ruling, the court determined that the medical care provided to prisoners must only be "reasonable," not necessarily "perfect, the best obtainable, or even very good." Relevant federal legislation and standards Currently, no national agency monitors the treatment of prisoners, although a few governmental and non-governmental agencies do provide monitoring standards that facilities may use if they wish to become accredited (about thirty percent of prisons are accredited), and some federal legislation has been passed regarding correctional health care. Federal Prisoner Co-Payment Act (1999) This legislation required that incarcerated individuals pay for some of their health care bill while in prison. Prison Litigation Reform Act (1996) The Prison Litigation