Eric Bodin

Director, VDH Office of Licensure and Certification

9960 Mayland Drive, Suite 401

Henrico, VA 23233

My name is Dr. Willie Parker and I am writing in response to the State Board of Health’s request for public comment regarding the regulations of abortion providers in 12 Va. Admin. Code §§ 5-412 et seq. As a physician that provides safe, quality abortion care, I urge the Board to repeal or significantly amend the regulations.

I have devoted my career to helping women have the families they want by supporting early and comprehensive prenatal care, preventing unintended pregnancy with medically accurate sex education and evidenced-based contraception, delivering babies, and providing safe abortion care. Given my 20 plus years of providing this care, I know these regulations threaten the health and safety of Virginia women seeking safe, legal abortion care.

In recent years, states have passed numerous measures that restrict abortion care that are not based on medical evidence and do nothing to benefit patients. These states include Mississippi, where I provide care, and Virginia.

Like Virginia, Mississippi legislators passed legislation that is targeted regulation of abortion providers (TRAP). Mississippi’s law is a bit different than Virginia’s law: it restricts the provision of abortion care to obstetrician/gynecologists with hospital admitting privileges. This law, which is completely unsupported by evidence-based medicine, would shut down the one remaining abortion clinic in the state, effectively denying women access to abortion care. On top of this, the state mandates delays that are costly and burdensome. A women’s access should not be denied simply because she lives in Mississippi. The care she receives should be determined by medical evidence, not by her zip code.

Although the Virginia regulations are somewhat different than that in Mississippi, the regulations represent another version of an unnecessary and medically unjustified TRAP law. What is similar between the two laws is that if Virginia women’s health centers that provide first-trimester abortion care are required to follow the regulations, some may be forced to close and women’s health will be in danger. I have already seen in other states where TRAP laws have passed.

As an abortion provider, I know that these regulations that require woman’s health centers that provide first-trimester abortion care to maintain extensive physical plant requirements are medically inappropriate. First-trimester abortion care is a simple surgical or medical procedure that is typically provided in an office-based outpatient setting. Abortion care provided in this setting is very safe and complications are extremely rare. As a result, the extensive physical plant requirements are medically unnecessary. In no way do they improve patient health and safety, and instead were clearly designed to impose medically unnecessary burdens on first-trimester abortion care.

As written, these regulations will do just the opposite of improving patient health and safety, by cutting off Virginia women from medical care for no legitimate medical reason. As I have seen in Mississippi, the decrease in access to abortion care will disproportionately harm women in groups that already face significant barriers in accessing health care, such as women of color, young women, rural women, and women without health insurance.

I urge you to repeal the regulations or amend them to address these concerns.  Thank you for your consideration.

Sincerely,

Dr. Willie Parker