I strongly urge the VA BOH to repeal the final regulations for women’s health care centers which forces current providers of first trimester abortion to meet stricter physical plant standards than any other health care facility in the state – stricter than hospitals, nursing home facilities, hospices, and outpatient facilities. I also oppose the requirement of any existing hospital to come into compliance with Guidelines for Design and Construction of Health Care Facilities, which are specifically intended to apply only to new construction, not to existing facilities. These regulations ignore the recommendations and testimony of experts in the field of women's reproductive health and medicine, and these regulations create an undue barrier in terms of women's rights to access to legal healthcare. 

Failure to repeal these burdensome guidelines to existing facilities will only result in further limiting access to health care, which is in conflict with the American Medical Association Code of Ethics, item IX: "A physician shall support access to medical care for all people." Additionally, it is my belief that in disregarding the testimony and recommendations of many experts in the fields of obstetrics, gynecology and women's health, the actions of the Board of Health are in conflict with item V of the Code of Ethics: "A physician shall continue to study, apply, and advance scientific knowledge, maintain a commitment to medical education, make relevant information available to patients, colleagues, and the public, obtain consultation, and use the talents of other health professionals when indicated." 

There is still time to rise to the standards and ethics of your profession. Please repeal.