Virginia Regulatory Town Hall
Agency
Virginia Department of Health
 
Board
State Board of Health
 
chapter
Regulations for the Licensure of Hospitals in Virginia [12 VAC 5 ‑ 410]
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5/23/13  9:05 pm
Commenter: Rhonda Hening Davis

Request to Amend Regulations for Licensure of Hospitals
 

 

Members of the Board of Health,
 
You have received numerous emails addressing the restrictive regulations of Abortion Care Providers. You are aware of the the precedent that these regulations place upon clinics around  the state.  I will not bore you with the reiteration of these regulations. I would like to cut to the chase.
 
You know why these restrictions have been put into place, and you know that not grandfathering existing clinics that have operated safely for years is a direct target to clinics that provide essential services to women's health that have nothing to do with abortions, but that do include abortion services. 
 
You know that the performance of abortion services are less dangerous to the patient than many plastic surgery or oral surgery services provided to patients, whose clinics will continue to operate without the same regulations applied to their architectural structures. 
 
You know that boards in the past have grandfathered existing medical facilities that provide essential medical procedures without restrictive measure, because they were found to be performing safely under their existing conditions, thus the grandfathering-in of their facilities. 
 
You know that you have been placed in a political position, and that your job is to use your medical expertise to act in a manner that reflects your medical experience to protect and provide safe treatment and care of citizens, regardless of political intervention. You realize that you are a check and balance of our state government, and that your medical expertise and your oath to provide safe care for patients is your primary goal. 
 
You realize that Roe v. Wade allows for abortions to be performed legally nationwide. 
 
I am asking that you use your common sense, as well as your medical expertise, to apply regulations either across the board to all medical facilities, or to refute all of the past boards that have grandfathered-in prior facilities as acceptable. 
Your decision will affect the health of women statewide. In fact, your decision will affect every citizen--every man, woman, and child--statewide. By voting to apply regulations to a selective health care facility, you have negated every grandfathered-in health care facility that has been approved in the past. 
 
As a citizen of the state of Virginia, I am asking that you use logic, rather than political pressure, to formulate your opinions of regulations. I am opposed to targeted regulations of one particular type of facility, while other types of health care providers are not included. I am opposed to the idea of not grandfathering-in currently operational clinics that provide safe, legal abortions every day without incident. 
 
I am opposed to the Attorney General' s threats to the Board of Health, regarding the clinics that perform more than 5 abortions each month. To bow to the Attorney General's political will was an act of ignoring your responsibility to Virginians to provide them with safe medical care. 
 
You were appointed to your positions due to your medical expertise, not your political expertise. If you feel that you were appointed otherwise, or if your opinions are not completely medically based, I would ask that you resign your position from the Board of Health.  You are not serving the public as indicated by the Board of Health.
 
If you are presiding on the Board of Health, as a true representative of the health of Virginia residents, you will grandfather the health clinics that provide abortion services, because they provide essential services to citizens, just as other less-regulated clinics, or grandfathered-in facilities do. 
 
I cannot be more forthcoming of my opinion of the targeted regulations, as well as of the currently approved  grandfathered-in health care facilities and hospitals that have been approved in the past.  
 
As the old addage provides, "What's good for the goose is good for the gander."  If these regulations cannot be applied to all clinics and hospitals that are currently in operation, then the Board of Health is essentially null and void.  You must provide your expertise in order to regulate health care that provides for all constitutionally approved medical facilities in the state. If you don't, then you must agree that all prior grandfathered health care facilites are in violation of the state's regulations, and must be closed down immediately. 
 
Thank you for your time, and professional MEDICAL expertise.  
 
Rhonda Hening Davis
CommentID: 28221