I don't envy you OLC, VDH and BOH folks

You have many comments, many opinions, many misrepresentations and MANY FACTS to sort through as you attempt to develop permanent minimum regulations to apply solely to abortioncare providers.

As an administrator at a doctors’ office that provides abortioncare and other  gynecologic treatments and procedures it may surprise you to know I am not opposed to reasonable licensure  and inspections. (We are already certified and inspected by 4 other entities - and all the doctors are vetted by OLC) However,  I do think that VDH has some needs to monitor morbidities and hospitalizations and deaths that may be the result of treatments at a doctors office, at a medical center or at a surgicenter. You already track immunizations and use CDC  for trends. It should be something to have reported across the board of medical service provision.

Bob Marshall in a televised interview pointed out the gap in VDH statistics collection.  I only wish he had been willing to address that but instead he dropped atomic bombs to do everything but.  Applying new construction surgical center building guidelines to established or emerging doctors offices is just un-defendable.  Requiring bihourly air exchanges in a doctors office is indefensible. Please involve actual businesses that provide these services in a stakeholder’s panel to assist you redefine the regulations..and I urge you to read the legislation again...It asks for MINIMUM requirements. Once you revise the regulations please hold public hearings.

Find the real needs, the real gaps and address those. Let us get back to practicing medicine and servicing the women of Virginia, one in three who have had safely or will continue to require abortion care.  And insure she can continue to do this with services provided by her doctor who she knows and trusts.