Agencies | Governor
Virginia Regulatory Town Hall
Virginia Department of Health
State Board of Health
Regulations for Licensure of Abortion Facilities [REPEALED] [12 VAC 5 ‑ 412]
Action Amend the Regulation after Assessment and Receipt of Public Comment
Comment Period Ends 10/31/2018
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10/26/18  12:50 pm
Commenter: Rose Codding, Falls Church Healthcare Center

Promulgate Guidelines that apply equally to all Medical Practices

Thank you for the opportunity to comment on this NOIRA.  Let’s call it like it is. Under the guise of women’s health and safety, politicians singled out only abortioncare providers and pro-choice gynecology practices for onerous and unnecessary restrictions. Though Virginian’s may never agree about abortioncare we all agree that citizens are entitled to their doctor - patient relationship. If Virginia’s Department of Health truly wanted to implement its Virginia Plan For Well Being (2016 – 2020) that honors The VDH Mission, the Board of Health would provide best practice guidelines and licensure that applies equally to every medical practice in the Commonwealth and assure access to healthcare be increased. 

I commend the VDH’s commitment to public health. Its Mission “To protect the health and promote the well-being of all people in Virginia. Its Vision “To become the healthiest state in the nation” by celebrating its Core Values “Our culture values service, equity and making data-informed decisions” by utilizing five goals, three I share here:


Foster healthy, connected, and resilient communities Implement population health strategies in Virginia. Foster community collaboration. Share timely, reliable, actionable, sub-county level data.


Be a trusted source of public health information and services. Deliver public health information accurately and timely in the format and delivery method in which it is most effective. Create systems, policies, and practices that improve health for all people in Virginia. Make our services more clear and visible to the public user. Reinforce the role and mission of public health to federal, state and to local communities.


Assure the conditions that improve health opportunity. Build partnerships at the state and local level to increase community capacity to focus on determinants of health. Enact “health in all policy” approaches at the state and local level. Strengthen organizational infrastructure to support health equity.

However promulgating regulations that only apply to pro-choice providers and not other healthcare providers or other medical services does nothing to promote health and wellness nor does it serve Virginia Department of Health’s mission. This is especially disturbing because the vast majority of Virginians support a woman’s right to access safe and legal abortioncare. That unwavering support puts us in step with the rest of our country and acknowledges that the Constitution protects a woman’s right to seek legal healthcare.

As the founder and director of  Falls Church Healthcare Center, a Virginia reproductive health care provider, I can tell you that promulgating restrictive regulations will have nothing to do with improving women’s health care. The old regulations existed only to create barriers between a woman and her constitutionally guaranteed right to access abortioncare; barriers that make it harder for health centers like mine to provide essential health care. As someone who works every day for the women impacted by these non-data based restrictions, I can tell you that these burdens are more than a mere inconvenience or increase the cost of healthcare. They are insulting, dehumanizing and often devastating for the women forced to endure them. For many women – especially those living with severe economic challenge or in rural communities or communities of color – these burdens can mean the difference between accessing essential care or being relegated to the status of second-class citizens. For these women, the guaranteed protections of the law now exist on paper only.

May I suggest that during your process you start over so to expand guidelines to include all medical providers, regulations that only increases access to healthcare and insure that the doctor/patient relationship can be protected.


CommentID: 68358