Testimony of Sara Imershein, MD, MPH, FACOG

Thank you for the opportunity to offer my expert testimony about Virginia’s current, and onerous, licensing regulations of abortion Facilities.

I am an expert in women’s health care and currently work as an OB-GYN in Virginia. I have been practicing medicine for three decades, including providing safe, legal abortion. I obtained my undergraduate education receiving a B.A. from the University of Pennsylvania, my medical degree from Emory University, and completed my internship and residency at the New York University–Bellevue Medical Center. I received a Masters of Public Health, concentrating on Health Policy from the George Washington University School of Public Health in 2012, and I hold the position of Associate Clinical Professor at the George Washington University School of Medicine and Health Sciences. I also work weekly at Falls Church Healthcare Center, Falls Church, VA. I am Board Certified in Obstetrics and Gynecology.

I write to you today urging you to repeal and rewrite current restrictions on women’s health centers in the Commonwealth. While others might argue – correctly – that current Targeted Regulations on Abortion Providers (ie: TRAP restrictions) were publicized and/or enacted without following the principles in Executive Order 14 (2010), I will specifically address “whether the regulation (i) is necessary for the protection of public health, safety, and welfare ….”

The answer is no. Currently TRAP restrictions have absolutely nothing to do with protecting women’s health and safety, and in fact only endanger women’s health by restricting access to critical reproductive services.  Long ago numerous rigorous scientific studies confirmed that abortion services could be safely provided in free-standing clinics and physician offices, without regulation beyond the prevailing medical standards of care. Restrictions, burdensome regulations, and unnecessary architectural requirements currently applied to women’s health centers in the Commonwealth ignore the body of medical literature and the reality of abortion care.

Abortion occurs in every state in the United States, and in every country in the world. The single factor most associated with safety is its legal availability. The next most important criterion for safety is the availability of the procedure as early in pregnancy as possible.

The current misguided and burdensome regulations create barriers to access of safe, legal medical care – increasing it’s danger by causing delays. The architectural requirements are not medically advised, and have never been shown to increase patient safety or satisfaction – but only serve to increase costs, decrease the number of healthcare providers and increase distances patients need to travel – negatively impacting the patients, and their families.

Science, and public health must dictate health policy – not politics. As a medical professional and an abortion provider in Virginia, I understand just how medically-unnecessary and dangerous the current restrictions are. I urge the Department of Health to amend and/or rewrite current regulations to conform with best medical practices and scientific, evidence-based fact.

Thank you for your consideration.

Submitted to the Virginia State Board of Health

Virginia Department of Health

July 28, 2014