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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3/6/13  8:19 am
Commenter: Melissa Nemeth

I Oppose TRAP
 

•  Women’s health centers will be forced to close because they cannot meet the new requirements.  TRAP laws require existing women’s health centers to come into compliance with three chapters of a manual called the 2010 Guidelines for Design and Construction of Health Care Facilities within the next two years. These Guidelines, however, are intended to apply only to new construction, not to existing facilities, which is how they are applied to every other health care facility in Virginia. Women’s health centers performing abortions should not be singled out.

 

• If health centers manage to stay open, the cost of abortion procedures will rise so much that some women can no longer afford them.  VDH estimates that complying with TRAP laws may cost women’s health centers over $2.5 million.  This high cost could force health centers to pass the expense on to patients, making it impossible for women to afford and access the services they need. 

 

•  TRAP laws will hurt women as well as men, restricting access to a wide range of preventive reproductive healthcare services, including life-saving cancer screenings, family planning and STI testing and treatment, as well as early abortion.

 

•  TRAP laws jeopardize the safety of abortion providers.  Abortion providers are often the targets of violence by anti-abortion extremists. The history of harassment and violence directed against professionals who provide abortion care makes it clear that confidentiality protections should be a part of the regulations to make sure that sensitive information can’t get into the wrong hands. But these draft regulations contain no such protections.

 

•  Loopholes leave patient confidentiality unprotected. Patients are targeted for harassment outside health centers and there is a history of anti-choice activists seeking patient information in order to deter women from obtaining care.  The regulations contain several loopholes that allow inspectors to remove patient records from the facility, rather than requiring them to examine the records onsite, and allow inspectors to request a list of all current patients. These regulations should be rejected so women’s health centers can continue to provide safe, accessible, comprehensive health care.

 

•  There are no legitimate medical purposes for singling out abortion providers. Extensive construction requirements have no relation to the safety of the services that women’s health centers provide. Regulating abortion differently than other outpatient procedures that are safely provided in non-hospital medical facilities is playing politics with women’s health.

 

•  These regulations are contrary to Gov. McDonnell’s Regulatory Reform Initiative. Gov. McDonnell charged agencies with repealing unnecessary regulations that burden individuals, businesses and other groups, and identifying statutes that require “unnecessary or overly burdensome regulations.”  Yet, he signed off on these new rules governing women’s health centers that perform abortion, which are a prime example of the overregulation he is trying to reduce. 

 

•  These regulations threaten Virginia jobs and the economy. Women’s health centers are part of the small business community, which plays a vital role in the Commonwealth’s economy. The Virginia Department of Health estimates that complying with these regulations could force women's health centers to spend over $2.5 million. In an unprecedented governmental attack on a legitimate business providing a legal service, centers that cannot afford the unnecessary expensive renovations will be forced to close, eliminating jobs across the Commonwealth.