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 Amend the Regulation after Assessment and Receipt of Public Comment
Stage NOIRA
Comment Period Ended on 7/10/2019
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649 comments

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6/10/19  9:45 am
Commenter: Leslie Rubio

Abortion Regs
 

Medically unnecessary regulations are burdensome to women who seek abortion in Virginia.  

The current regulations provide NO medical or any benefit to women who seek an abortion.  Requiring women to undergo a 24 hour waiting period, and a medically unnecessary abdominal ultrasound only puts more of a burdon on women who seek safe and legal abortion services.  Requiring clinics to adhere to hospital standard building requirements does not make abortion safer; this regulation only seeks to shutter clinics that are already under increasing scrutiny and additional state requirements which are solely because they provide abortion care.  

Continuing to allow the State to impose these unnecessary and burdensome regulations ONLY to facilities and clinics that provide abortion care is NOT a medical standard!  Shaming women and causing them additional financial burden does not contribute positively toward their care, but instead creates additional hardship.

Please amend the regulations by removing them from the guidelines.

CommentID: 72532
 

6/10/19  7:50 pm
Commenter: Prabha Iyer

Remove unnecessary restrictions on abortion access
 

Please amend Virginia's politically-motivated Targeted Regulations on Abortion Providers (TRAP) regulations to reflect medicine and science. In 2016, the Supreme Court ruled in Whole Woman's Health v. Hellerstedt that restrictions that have no medical benefit and are designed simply to limit access to abortion and shut down healthcare clinics are unconstitutional. Virginia's architectural requirements are clearly unconstitutional under this standard. Further, the excessive administrative requirements present an additional undue burden to providers and patients in a blatant attempt to paperwork women's health centers out of business. 

As you consider amendments to Virginia's abortion provider regulations, I hope you will prioritize patient confidentiality and access to healthcare.  Please heed the expertise of doctors, medical professionals and legal experts and amend these onerous, medically-unnecessary, and unconstitutional regulations to be based only on science and the standard of care.

Thank you,

Prabha Iyer

CommentID: 72533
 

6/12/19  1:24 pm
Commenter: Joyce Samples

regulations of abortion facilities
 

Please amend Virginia's Targeted Regulations on Abortion Providers. Having women submit to additional, unnecessary tests creates more stress for the woman, as well as increases un necessary expenses to the provider. This is clearly aimed at controlling women and limiting healthcare.

CommentID: 72538
 

6/12/19  3:26 pm
Commenter: Jean Marie Ward

Amending TRAP
 

Please let medicine and science guide you in amending Virginia's Targeted Regulations on Abortion Providers (TRAP). Onerous, medically-unnecessary regulations hurt women and are unconstitutional. Science and medicine should guide health regulations, not politics. 

Thank you.

CommentID: 72542
 

6/12/19  3:28 pm
Commenter: Rebecca Cofman

TRAP amendments
 

Please let medicine and science guide you in amending Virginia's Targeted Regulations on Abortion Providers (TRAP). Onerous, medically-unnecessary regulations hurt women and are unconstitutional. Science and medicine should guide health regulations, not politics. 

CommentID: 72543
 

6/12/19  3:56 pm
Commenter: Valerie Stucky

TRAP regulations
 

Medically-unnecessary regulations of abortion clinics are unconstitutional.  Regulations should be guided by medical science, not politics.

CommentID: 72544
 

6/12/19  3:57 pm
Commenter: Kris McLaughlin

TRAP
 

Please let medicine and science guide you in amending Virginia's Targeted Regulations on Abortion Providers (TRAP). Onerous, medically-unnecessary regulations hurt women and are unconstitutional. Science and medicine should guide health regulations, not politics. We don't need to restrict medical care; rather, our aim should be to expand care. 

CommentID: 72545
 

6/12/19  5:00 pm
Commenter: Bruce Hill

Regulations for Licensure of Abortion Facilities
 
CommentID: 72548
 

6/12/19  5:08 pm
Commenter: Bruce Hill

Regulations for Licensure of Abortion Facilities
 
CommentID: 72549
 

6/12/19  5:24 pm
Commenter: Jessica Moore

Scrap TRAP, Support full access to reproductive health services for women
 

Please stop the assault on women’s health care services for reproduction.

Please let medicine and science guide you in amending Virginia's Targeted Regulations on Abortion Providers (TRAP). Onerous, medically-unnecessary regulations hurt women and are unconstitutional. Science and medicine should guide health regulations, not politics. 



CommentID: 72550
 

6/12/19  7:37 pm
Commenter: Kelly Haber RN

TRAP is wrong minded
 

Women's bodies and women's health care should not be political pawns. Women deserve to have safe, affordable contraception and access to abortion. Do not support TRAP. Advances in contraception have already reduced the incidence of women seeking abortion. Let this trend continue to manifest change and don't force people to have unwanted children. How can this be good for society? Isn't there enough child neglect and abuse to deal with already without forcing people to bring unwanted children into the world. Look at the big picture, the long range view and don't get trapped in the current ignorance and fear. 

CommentID: 72553
 

6/12/19  8:40 pm
Commenter: Barbara Seaman

TRAP Should Be Abolished
 

TRAP has nothing to do with medical necessity. It’s nothing but a political ploy designed to make a woman’s need for abortion as difficult as possible.

CommentID: 72554
 

6/12/19  9:00 pm
Commenter: JESSE A RABINOWITZ

Scrap TRAP
 

Scrap TRAP and every other attempt to rob women of their autonomy.  We are a pluralistic republic, not a theocracy. 

CommentID: 72555
 

6/12/19  9:10 pm
Commenter: judy marie johnson

repeal sham trap restrictions, respect the medical and science findings, respect choice
 

CommentID: 72556
 

6/12/19  9:49 pm
Commenter: Susan G. Bramley,

TRAP
 
I am writing to ask you to please let medicine and science guide you in amending Virginia's Targeted Regulations on Abortion Providers (TRAP).  Medical procedures should be based on medical best practices, not the ideas of politicians.  Please help protect women's health by eliminating medically unnecessary procedures and exams from the abortion procedure.  Onerous, medically-unnecessary regulations hurt women and are unconstitutional. Science and medicine should guide health regulations, not politics. 




CommentID: 72558
 

6/13/19  6:37 am
Commenter: Tracy Hoffman

TRAP- Onerous TRAP regulations hurt women
 

Please let medicine and science guide you in amending Virginia's Targeted Regulations on Abortion Providers (TRAP). Onerous, medically-unnecessary regulations hurt women and are unconstitutional. Science and medicine should guide health regulations, not politics.

CommentID: 72559
 

6/13/19  9:04 am
Commenter: Karen Salmonson, R.N.

TRAP
 

Please do not keep these regulations. If abortion clinics have these onerous regulations, then ALL outpatient clinics should have the same ones. 

CommentID: 72560
 

6/13/19  9:37 am
Commenter: Molly DeMaret-Tahu

TRAP: Science and Medicine, not politics
 

Onerous, medically-unnecessary regulations hurt women and are unconstitutional. Please let medicine and science guide you in amending TRAP. Politics have no place in these decisions. 

CommentID: 72561
 

6/13/19  10:02 am
Commenter: Stephanie Malady

Scrap TRAP
 

Many medical procedures, including childbirth, are far more dangerous to patients, yet are not subject to ambulatory surgical-center requirements. It is imperative that Virginia's anti-choice Targeted Regulations on Abortion Providers (TRAP) regulations be amended to reflect medical need.

Access to the full range of reproductive healthcare is critical to facilitating the well being of Virginia residents. Implementation of costly, medically unfounded regulations that hinder access to critical health services for the general population is in direct opposition to your mandate.

Furthermore, not only are these regulations medically unsound, they have been found to be unconstitutional.  In 2016, the Supreme Court ruled in Whole Woman's Health v. Hellerstedt that restrictions that have no medical benefit and are designed simply to limit access to abortion and shut down healthcare clinics are unconstitutional. Virginia's TRAP architectural requirements are clearly unconstitutional under this standard.

CommentID: 72564
 

6/13/19  10:39 am
Commenter: Pam Pouchot

TARP onerous regulations
 

The science of medicine must be the ruling factor when deciding regulations for abortion providers.  Neither religion or politics have a place in this discussion.  Over-regulation to make abortion inaccessible is a political decision.  To determine when a fetus has a soul is religious doctrine.  I would truly prefer you spend more time, effort and money on making birth control free or truly affordable to prevent unwanted pregnancies in the first place.  The government does not belong in a woman's uterus.  Any loss of autonomy over a woman's own body is the definition of slavery. 

CommentID: 72565
 

6/13/19  11:11 am
Commenter:  

War Against Women
 
  • TRAP Laws sole purpose is to stop women's reproductive health services. TRAP is a trap. Purely political with no basis in science. Endangering and punishing women.
CommentID: 72566
 

6/13/19  11:57 am
Commenter: Donna McCauley

Eliminate TRAP
 

I am writing to urge the Board to eliminate TRAP regulations that are not medically necessary but represent an attempt to undermine the availability of abortions. Abortions are legal, as determined by the Supreme Court in Roe v. Wade. They should be available and accessible according to a decision-making process undertaken by a woman and her doctor, NOT by legislators. Women's rights should not be abrogated by political subterfuge.

Thank you.

 

 

CommentID: 72569
 

6/13/19  12:02 pm
Commenter: Erin Burnette

Science and medicine should guide health regulations, not politics.
 

Protect women’s lives and medical decisions by keeping politics out of health care decisions. Science and medicine should guide health regulations, not politics. 




CommentID: 72570
 

6/13/19  4:48 pm
Commenter: Kaye Kory

A woman should make her own personal healthcare decision
 

Regulations for women's healthcare clinics should grounded in fact, not political points of view condemning the healthcare services offered.  Healthcare should be provided in a setting that has proven to be safe.  Personal healthcare decisions are private and made between patient and doctor. 

No member of the General Assembly was elected to dictate healthcare decisions for any man, woman or child in this Commonwealth. this text and enter your comments here. You are limited to approximately 3000 words.  #scrapTRAP

CommentID: 72572
 

6/13/19  6:34 pm
Commenter: Lynn West

TRAP regulations
 

The government has absolutely no business regulating decisions a woman and her doctor make about her body.  You will never stop terminations - only make them unsafe. 

CommentID: 72573
 

6/14/19  1:11 pm
Commenter: Carolyn Johnson

A woman's health decisions should be between her, her doctor, and her God. Eliminate TRAP
 

CommentID: 72574
 

6/17/19  9:56 am
Commenter: Penelope Smith

TRAP REGULATIONS
 

Do not allow these useless regulations to affect the health care of women in Virginia. There is no public health care crisis for women seeking safe legal abortion in Virginia.  Abortion complications are a fraction of 1%. Abortion care is a health issue not a political one. These needless regulations harm patients and burden abortion care providers. This licensing scheme has no legitimate medical basis. These regulations do not make abortion safer and only make it harder for Virginians to access safe and legal abortion care .

CommentID: 72579
 

6/20/19  8:49 am
Commenter: Isela C.

Eliminate TRAP
 

Please eliminate these regulations that only create barriers for women to get safe, legal abortions. These laws should not be made based on opinion, religion, or politics. They should be based on science.

CommentID: 72612
 

6/20/19  10:33 am
Commenter: Catherine Poole

T.R.A.P. laws
 

Eliminate T.R.A.P. laws. They are an unnecessary burden on women.  

CommentID: 72616
 

6/20/19  10:55 am
Commenter: Neha Mistry

#ScrapTrap - Medically Unnecessary and Unconstitutional Restrictions
 

Virginians are fed up with the medically unnecessary and unconstitutional restrictions on their right to receive safe and legal abortions from their abortioncare providers.   These restrictions do not protect patients, they cause undue burden and hinder patients' reproductive freedoms.

CommentID: 72617
 

6/21/19  8:50 am
Commenter: LaChanda Marie Mills

TRAP Regulations are inconsistent with medical best practices;
 

Abortion is one of the safest outpatient procedures in modern medical practice, safer than many other gynecologic procedures; safer than having a colonoscopy, safer than having a dental procedure.

The additional TRAP regulations do not provide any additional safety. Abortion providers are already faced with regulating agencies that ensure safety, just like all other medical facilities. 

TRAP regulations target abortion facilities by requiring medically unnecessary and administrative burdens that could actually harm patient healthcare (ie; requiring a woman to a waiting period that could disqualify her from safe abortion to now requiring a more invasive procedure determined by her gestation, requiring state mandated paperwork that is inaccurate while potentially making her travel for healthcare services in a state where she doesn't live, emotionally taxing for women as they are asked by inspectors to be allowed to observe her procedure)

TRAP regulations do not provide a medical benefits, and serve no purpose in the common gynecologic practice of abortion. 

-LaChanda

 

 

CommentID: 72627
 

6/21/19  11:49 am
Commenter: Lila Weintraub DC Doulas for Choice

Scrap Trap
 

As an abortion doula and social worker in Virginia and DC I have seen the devastating effects of medically unnecessary restrictions and mandates on abortion. I urge you to stand against these TRAP laws.

 

Sincerely,

Lila Weintraub

CommentID: 72628
 

6/21/19  11:58 am
Commenter: Emily Stets, DC Doulas for Choice

NO TRAP
 

Please amend Virginia's Targeted Regulations on Abortion Providers. Having women submit to additional, unnecessary tests creates more stress for the woman, as well as increases unnecessary expenses to the provider. This is clearly aimed at controlling women and limiting healthcare.

CommentID: 72629
 

6/21/19  4:19 pm
Commenter: Stephanie Clark

Regulations for Licensure of Abortion Facilities
 

I write today to beseech you to protect the right of women to determine what's best for themselves and their families. TRAP laws have been designed to target facilities because the opponents of a woman's right to choose know that they can't convince a majority of voters to overturn federal protections for abortion. Let Virginia establish and protect a proud tradition of respecting the moral authority each of us has in arranging our own lives. 

CommentID: 72630
 

6/21/19  6:12 pm
Commenter: Ahmad Kabiri

Stop the TRAP regulations
 

The TRAP regulations had no medical benifit except to put unnecessary burden on abortion providers and the women the desperately need this service. The main purpose of the regulations are to limit abortions by making it difficult for the women who want to have abortions. THE PURPOSE IS SO PAIN TO SEE, ANOTHER WAY TO LIMIT THE RIGHT OF WOMEN TO CHOOSE. 

CommentID: 72632
 

6/23/19  11:30 am
Commenter: Robert C. Kiser

Someone I love very much died because Roe v. Wade did not exist when she was 17.
 

Someone I love very much died because Roe v. Wade did not exist when she was 17. Follow the Golden Rule. Treat others as you would like to be treated. Mind your own business. 

CommentID: 72636
 

6/23/19  4:29 pm
Commenter: Natalie Rader

Protect Reproductive choice and access to safe and legal abortion
 

please protect women’s access to safe and legal abortion.  Please look at the scientific literature showing that abortion is safe as it is!   There do not need to be more regulations making it harder for women to access care.  I had 2 abortions at a young age.  One was in Ohio with a waiting period and a h doctor at a private clinic.  I had complications afterward and was lucky I could talk to a physician without threat of legal action.  The second was in Colorado in a planned parenthood and it was a supportive and caring environment and I experienced no complications.  I am so grateful for the ability to do this safely.  Otherwise I would have done it unsafely.  

Please protect this right.  We need it.  Our daughters need it. It is your duty.  Please support planned parenthood and a woman’s right to choose.  

CommentID: 72637
 

6/23/19  4:50 pm
Commenter: Louise Smith

Please support reasonable reproductive choices for women
 

Please consider seriously supporting reproductive choices for women including access to safe abortions.  Please do not burden this choice with medically unnecessary and invasive tests and other conditions.  This is very important for all women and for society.

CommentID: 72638
 

6/24/19  9:48 am
Commenter: Margaret A Miller

Abortion regulations
 

It is hard for me to believe that the board is considering reinstating the onerous and medically unnecessary TRAP regulations. Those regulations were developed to discourage women from exercising their Constitutionally protected right to control their own reproduction. Please do not contribute to the removal of rights from more than half the citizens in the state.

CommentID: 72659
 

6/24/19  7:54 pm
Commenter: Diane Berlin

Scrap TRAP!!!!
 

THESE ARE OUR BODIES! THEY WERE NEVER INTENDED TO BE UNDER THE JURISDICTION OF THE GOVERNMENT! SCIENCE AND MEDICINE ALONG WITH EVERY WOMAN’S FREE CHOICE SHOULD DETERMINE HER FUTURE -  NOT SOME HOLIER THAN THOU AUTHORITARIAN MEN IN SOME GOVERNMENT TRIBUNAL! DO THE RIGHT THING!!!!!

CommentID: 72682
 

6/26/19  5:06 pm
Commenter: Nathan Alderman

Please end TRAP laws in Virginia
 

I understand that a federal judge has reimposed the TRAP regulations the Board of Health abolished in 2016, and obliged you to start the process of considering those rules all over again. As I'm sure you know, in 2016 the Supreme Court ruled similar regulations in Texas unconstitutional. Nor are the regulations you're considering necessary to protect patients' health; a 2018 study of 50,000 such procedures showed equally low complication rates in clinic or hospital settings (https://www.ansirh.org/sites/default/files/publications/files/safety_of_abortion_in_ascs_fact_sheet.pdf). These rules exist for purely political purposes, to impose the religious beliefs of a relative minority on the majority. While I sympathize with abortion opponents, and do not doubt that the majority of them are sincere in their efforts to preserve life as they see it, I think the unintended consequences of forcing everyone to follow their personal beliefs are too great to support. Please abolish these rules once again, keep clinics open, and preserve Virginians' control over their own bodies and health, and their access to safe medical care.

CommentID: 72750
 

7/2/19  7:11 pm
Commenter: W. KIng

Abortion regulations
 

Thomas Jefferson said; The Care of Human Life and Not their destruction is the first and only legitimate object of good government. 

Abortion proponents violate this first and foremost object of government. Pro-choice actually is a misnomer in that it removes all chance of choice for the unborn.

Please continue pro-life legislation 

CommentID: 72784
 

7/2/19  7:19 pm
Commenter: Richard W Firth

SHUT THIS CLINICS DDOWN BEFORE GOD SHUTS YOU DOWN
 

Abortion (GENOCIDE-HOLOCAUST) centers shouldn't get a free pass just because there's a pro-abortion executive in the Governor's mansion  and now, we have seen many hundreds of regulatory violations from inspection reports conducted in these facilities. They have shown only a glimpse of the filthy, careless, and dangerous conditions in many of these centers. One abortion center, Virginia Health Group, was so bad that even Gov. McAuliffe's own Health Commissioner shut it down within hours of an inspection of the facility triggered by a customer complaint. These regulations help ensure some accountability by shedding light into the pervasive darkness of an industry that has proven to care about profit at the expense of everything or anyone else.  GOD’S WRATH IS COMING IN THIS MATER.,  IN FACT IT IS ALREADY BEGINNING  WITH THE CATASTOPHIC WEATHER EVENTS NOW OCCURRING AROUND THE NATION, GETTING WORSE AND WORSE DERSTROYING BILLIONS OF DOLLARS WITH OF PROPERTY AND TAKING MANY LIVES AND WILL GET MUCH WORSE UMNTIL THIS NATION REPEMNTS OF THE SINS OF ABOMINATION IT IS NOW COMMITTING OW WHICH ABORTION IS ONE

CommentID: 72785
 

7/2/19  7:20 pm
Commenter: Al Yancey

Abortion needs oversight
 

I urge you to keep the regulations in effect. Making sure the facilities meet Virginia's medical standards is an important job for the Commonwealth in this area. Even if the outcome is not safe for one person involved (the baby), at least the mother will be protected from poor or neglected facilities.

CommentID: 72786
 

7/2/19  7:22 pm
Commenter: Laura S

Continue to enforce regulations on abortion facilities
 

I’m writing to request that you continue to uphold the regulations that are currently in place for abortion facilities. These facilities should be held to the highest of standards as they are caring for women that are already in difficult situations and don’t need complications or poor health standards to deal with on top of everything else. If we care about women and their choice we should care about giving them the safest place possible. Removing regulations is careless and takes a very serious procedure back to the alley. Just because our governor is the “Abortion for all, even at birth”, advocate, he doesn’t get a pass on doing things the right way. This in no way impedes women’s access to abortion care. If anything it points out those dangerous facilities that women should avoid. Let’s not make this political and about lining the pockets of the abortion industry. Let’s continue to care about the women we so ardently fight to protect. 

CommentID: 72787
 

7/2/19  7:39 pm
Commenter: Linda

All medical care should meet standards- even abortion clinics
 

i don’t understand why it is permissible to allow ANY medical clinic  to not meet excellent health care  standards. Why place women at risk and give them substandard oversight. Just because the clinic performs abortions. It is a travesty to think that women who have made that choice should have anything but excellent, clean, and proper medical care. Do not allow substandard oversight in the name of “pro- choice”.  If your daughter chose to have any medical procedure, would you allow lax oversight of the location of the services she chose??!!

 

 

CommentID: 72788
 

7/2/19  7:40 pm
Commenter: LaVerne Waybright

Abortion regulations
 

The abortion industry needs more regulations, not less.

CommentID: 72789
 

7/2/19  7:45 pm
Commenter: Ellie Gudeman

Abortion regulations
 

We strongly urge you to continue to uphold the regulations that are currently in place for abortion facilities. If a woman does decide to have an abortion, she should certainly be able to have access to clean and medically safe facilities.  Keep the current regulations!

CommentID: 72790
 

7/2/19  7:53 pm
Commenter: Mary Mann

The abortion industry needs more oversight, not less!
 

Abortionists can not be trusted.  They are blinded by the money they can make.

Clinics are often filthy.

One abortion center, Virginia Health Group, was so bad that even Gov. McAuliffe's own Health Commissioner shut it down within hours of an inspection of the facility triggered by a customer complaint. 

Please give women the advantage of a CLEAN facility, at least.

CommentID: 72791
 

7/2/19  7:55 pm
Commenter: Sarah Drain

Health regulations for abortion clinics
 

CommentID: 72792