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  1:00 pm
Commenter: Aaron Goldberg, American College of Obstetricians and Gynecologists

TRAP Regulations, Virginia Board of Health
 

I am an ob/gyn physician. I respectfully urge the Board of Health to reconsider the TRAP regulation restricting abortion clinics. These regulations provide nothing for patient safety and are clearly meant as a political effort.

Whatever your feelings of abortion, the procedures at a majority of clinics are proven safe and a likely safer than many other procedures performed as outpatients for other reasons.  The regulations will certainly restrict access to safe and legal 1st trimester abortion, but will also likely negative impact the provision of other vital servicse to women, such as reprodcutive counseling (that may help AVOID further abortions). In addition, the regulations are certain to be disproportionately burdensome to poor and disadvantaged women, furthering the existing inequality of our health care system.

Clinics that have failed to meet current standards should be dealt with appropriately, but the new regulations represent a burden that is largely without merit.
 
If the goals of the regulations are to improve patient safety, then the Board should convene an expert panel including medical experts from multiple areas of medicine to identify ALL outpatient procedures that need to be evaluated in terms of improving safety.  As a physician caring for women, it is my sincere hope that the regulations will be amended to be based purely on medicine and science and should not impede women's access to essential health care. 
 
Aaron Goldberg, MD, FACOG
Richmond, VA

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