Virginia Board of Health

I am writing to urge you to maintain the highest of standards in abortion clinics within our state. To do anything else is an abrogation of your duty and would come as a shock to the majority of citzens in our state who are unaware these deliberation are happening. Abortion is a surgical procedure and to allow these facitlities to operate without maintaining the standards of other out patient surgical facilites is accomodation that escapes reason. Why may I ask? These clinic by and large are money making ventures like any business and are free to make whatever decision they deem to necessary to protect their profit. Regulations by the state are the only sure way to make sure that cleanliness, safety, health, and overall professionalism, that all patients have a right to expect, are not being sacrificed for the almighty bottom line. Please do the work of the Board of Health and protect our citizens by maintaining the highest of standards. Virginians deserve no less.

Women's Safety is Paramount

Abortion center regulations are essential for the health and safety of Virginia women and must be maintained, not weakened.  Abortion is not healthcare because it ends lives instead of healing them. However, since abortion operates under the guise of healthcare, abortion centers must adhere to the regulatory standards of other healthcare facilities. It is unconsciencable that women would be subjected to anything less than the current regulations.  If anything, Virginia women deserve more not less.

Restore Safe Abortion Regulations for the Safety Of Virginia Women

The Virginia Abortion Regulations should not be further watered-down. Instead, the regulations which became effective on June 30, 2013 through the legal, required procedure with extensive public comment should be reinstated. The 2013 abortion regulations were watered-down following a nearly $2,000,000 donation from Planned Parenthood to the McAuliffe political campaign. Under the watered-down regulations, numerous health, safety, and sanitary violations occurred in Virginia abortion facilities (See Virginia Dept. of Health Office of Licensure & Certification (OLC) inspection reports of Virginia abortion facilities during this period). Virginia abortion personnel are not capable of dealing with serious injuries to women undergoing abortion (See VA Health Dept OLC report of inspection at Falls Church Health Care Center on April 11 & 12, 2018, pages 28-33) and they don't report these serious injuries to the Virginia Health Dept.The current watered-down abortion regulations are not safe for Virginia women. They must be restored to a safe level and enforced. 

Here are a few changes I recommend the Board consider:

1. Reinstate all the health and safety measures the Board unlawfully watered down during its last amendment process. 
2. Require all OLC inspections to verify that ultrasounds have been performed at least 24 hours prior to every abortion performed. 
3. Require annual inspections on abortion facilities instead of biennial. 
4. Remove the ability of the Commissioner to grant permanent variances.
5. Reinstate the definition of "first trimester" as being the first twelve weeks from conception, not "13 weeks and 6 days after last menstrual period." 
6. Reinstate the ability of the department to deny, suspend, or revoke the license to operate an abortion facility for violating "any provision of Article 1 (§ 32.1-123 et seq.) of Chapter 5 of Title 32.1."
7. Reinstate the requirement for abortion facilities provide information on post-abortion counseling to its patients.
8. Reinstate the requirement that the abortion facility ensure that it has removed all of the fetal body parts from inside of the female patient upon the performance of an abortion. 
9. Reinstate the requirement that abortion facilities report to OLC any incidents reported to the malpractice insurance carrier.
10. Reinstate the reasonable design and construction standards that provided for things such as hallways wide enough to carry patients out on stretchers in cases of emergency.

 Thank you for your consideration.