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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3/29/13  1:04 pm
Commenter: Sheena Mayfield

Please Make Fair Decisions Based on Science
 

I strongly urge you to oppose the new "Regulations for Licensure of Abortion Facilities," or at the very least amend them to ensure they are truly medically necessary, evenly applied, and consistent with patient privacy and confidentiality as required by HIPPA.

According to the Supreme Court of the United States abortion is a legal medical procedure, and regulations targeted solely at this specific procedure are only intended to prevent access and are unconstitutional. If legislators and The Board of Health truly felt that these new requirements were the only way to protect the health and safety of the men and women of the Commonwealth then they should apply to every other ambulatory surgical facility as well.

However, even if such regulations were deemed necessary, in all instances in which the Board of Health has previously regulated health care facilities, new regulations have applied only to the "construction of new buildings and additions, alterations or repairs to existing buildings.” This means that existing facilities, which were not planning on undergoing significant construction or renovation, were not required to meet new building standards (see Virginia Department of Health, Office of Licensure and Certification, Design and Construction of Health Care Facilities, July 1, 2006) Specific  issues of violations and legitimate safety concerns should be handles as such; specific cases with specific medically necessary upgrades.

As it stands The Board of Health already has regulations that cover first trimester abortions, and these procedures are already some of the safest outpatient procedures currently being preformed in Virginia. As such these regulations are intended to make abortion services unavailable in the Commonwealth, under the guise of "helping" women. However, they will have the opposite effect. Clinics that provide abortion services also provide affordable care for cancer screenings, gynecological exams, prenatal care, sexually transmitted disease testing and treatment, family planning, and even adoptions. The women of Virginia need more access to these services, not less. Imposing these regulations will further marginalize young, low-income, uninsured and minority women by decreasing their access to affordable health care options. This is an egregious misuse of power by legislators that is wholly removed from factual medical risk data.  Regulations should not be used as a political weapon, and it is highly inappropriate to substitute medical knowledge with religious and political feelings in the development of such regulations. 

While I understand that abortion has supporters and detractors, the legality of that medical procedure is not the issue here, and I appeal to you to ignore outside political influences and urge you to make an impartial, professional decision based on sound scientific information. The integrity of the Board is at stake.