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 Regulations Following Periodic Review
Stage Proposed
Comment Period Ended on 7/1/2016
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6/30/16  11:42 pm
Commenter: Michael Harlow

Amendments Go Against Health Commissioner's 2016-2020 Virginia Plan for Well-Being
 

The Health Commissioner's 2016-2020 Virginia Plan for Well-Being: AIM 4: System of Health Care states, "The challenge for Virginia is to improve health care quality by providing care that is safe, effective, patient-centered, timely, efficient, and equitable while controlling health care spending." 

However, the Health Commissioner recommends removing requirements from the abortion regulations that would achieve this challenge of quality healthcare with controlled spending. Requirements such as post-abortion counseling, STD screening, pathologic examination of tissue and written agreements that would incur no further health care costs since abortion clinics are already providing these services.

The Health Commissioner's 2016-2020 Virginia Plan for Well-Being lists as Foundational Goals for AIM 4: System of Health Care, "Virginia assures adequate regulation of health care facilties," and "Virginians obtain, process, and understand basic health information and services needed to make appropriate health decisions." 

By removing evidence-based requirements from the regulations, Virginia will no longer be assuring adequate regulation of its healthcare facilities. 

It also makes it more difficult for Virginians to make appropriate health decisions. When a woman struggles with "depression, shame, guilt or regret" after having had an abortion, but has not been given resources to deal with those feelings, she is not able to make appropriate health decisions. When a woman has an undiagnosed STI and is not given a screening at the abortion facility, she is not able to make appropriate health decisions. When an abortion cannot be confirmed and a woman is not evaluated further because she can't afford to, she is not able to make appropriate health decisions. If an emergent complication occurs at an abortion facility with no agreement with a nearby hospital, making sure the patient isn't just dropped off but receives quality care, she is not able to make appropriate health decisions.

I recommend retaining post-abortion counseling, STD screening, and transfer agreements, and removing any cost-based decision-making evaluation of tissue.

CommentID: 50502