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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1/29/13  10:40 am
Commenter: Lynn W

Targeted regulations for women’s health centers in Virginia (aka TRAP regulations)
 
I am a woman who has lived in Virginia since early childhood, a woman who married and raised two children in the Commonwealth, a woman who built a successful career in the Commonwealth, a woman who has relied on the services of health care centers that would be affected by the proposed regulations.  I also am a woman who cares about the direction of Virginia and votes for elected officials who will protect the interests and needs of all Virginia's citizens.  I am strongly opposed to the proposed "TRAP" regulations for the following reasons. 
 
The proposed regulations will create extensive, burdensome requirements for clinic buildings that are unrelated to the services health centers provide, will reduce or eliminate patient access to health care, and will increase financial hurdles to health care for patients.  Despite these enormous flaws, the proposed regulations have no proven medical benefit to patients. Women of Virginia need more access to affordable, high quality health care, not less. 
 
Medically inappropriate and unnecessarily burdensome regulations such as the proposed TRAP regulations would restrict access to essential health care services for the women of Virginia and further marginalize young, low-income, uninsured and minority women by decreasing their health care options. These proposed regulations threaten the continued availability of preventive reproductive health care and of safe, legal first-trimester abortion in many locations throughout the state. There is no justification for implementing the regulations as proposed.  The high standard of care currently provided by women's health centers is proven by their impressive safety record. Abortion is one of the safest medical procedures.  The proposed regulations will do nothing to improve safety, but will do much to harm the health of many women throughout the Commonwealth.
 
Overregulation will limit access to a wide range of preventive reproductive health care services provided by women's health clinics, including life-saving cancer screenings, family planning, and sexually transmitted infection testing and treatment. The proposed TRAP regulations are not based on medicine or science, but rather, appear to be based on a misguided effort to force the majority of women’s health centers in Virginia to close their doors.  The unintended consequence of this will be an increase in undetected disease, an increase in unwanted and unplanned for children, and a decrease in the number of women who are able to contribute the economy and welfare of Virginia.
 
I was once a young, low income resident of Virginia who depended on the critical services these clinics provided.  Their services allowed me access to the medically necessary annual exams and screenings, as well as effective preventative family planning techniques that helped ensure I was able to obtain an education, build a productive career, create a healthy and happy family, and contribute to the Commonwealth's economy.
 
It is my hope that the regulations will be amended to be based purely on medicine and science and avoid impeding women's access to essential health care. If regulations placed on women's health centers are based upon evidence-based medical practices that advance the public health, then women in the Commonwealth will be able to maintain such access to vital health care from trusted medical providers.