Agencies | Governor
Virginia Regulatory Town Hall
Agency
Virginia Department of Health
Board
State Board of Health
chapter
Regulations for Licensure of Abortion Facilities [12 VAC 5 ‑ 412]
Action Regulations for Licensure of Abortion Facilities
Stage Proposed
Comment Period Ends 3/29/2013
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1/28/13  5:01 pm
Commenter: Ike Koziol, MD

Abortion clinic regulations
 

Dear Board members,

I have testified before the Board and at the General Assembly regarding abortion clinic regulations passed by the General Assembly and signed by the Governor.  I am a physician and in my work I use evidenced-based medicine as my "gold standard."  The word evidence means a fact or observation that proves the truth of a belief.  There is no evidence that abortion clinics are not safe and there is no evidence that new onerous regulations are needed.  If you allow these regs to go forward it will effectively close down many women's health center that provide needed care to thousands of women.  These centers do PAP smears and provide other non-abortion services.  There is no reason that politicians should dictate medical care since they are not doctors and know absolutely nothing about evidence-based medicine.  It is a SLIPPERY SLOPE that we are approaching and I would hope that you, as healthcare-involved professionals, would understand this reality.  An expert panel of OB-Gyn doctors understood this and they recommended against these changes.  Other doctors including representatives of the local American College of Obstetricians and Gynecologists and the Medical Society of Virginia and the Richmond Academy of Medicine understood this and asked you not to adopt these regulations.  You professionals in healthcare fields need not fear the Governor or Attorney General in their effots to intimidate you into adopting these regulations.  The AG will once again posture and ask you to adopt the regulatons.  Please stand up and be counted as not allowing politicians to get between a woman and her doctor.   You are under no obligation to adopt these regulations if you feel that they are improper and  unnecessary.  Your obligations, as I understand them, are to promote health issues that protect the citizens of the Commonwealth. 

My comments also apply to the unnecessary ultrasound requirement.  These are not medically necessary.  Medical necessity is usually defined as: 1) a procedure supported by articles in peer-reviewed medical journals, 2) a procdure supported by national guidelines as put forth by such groups as the AMA or American College of Obstetricians and Gynecologists .  Nowhere in medical necessity does it state that a procedure is medically necessary because a politician or government has mandated the procedure.  That mandate would actually be bad medicine.  Please do not support bad medical care.

Respectfully,

Ike Koziol, MD