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Regulations for Licensure of Abortion Facilities [REPEALED] [12 VAC 5 ‑ 412]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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10/31/18  3:29 pm
Commenter: Constance Cordovilla, VA chapter, National Organization for Women (NOW)

TRAP Regulations Should Protect Access to Health Care for All Women

I am writing on behalf of the Virginia Chapter of the National Organization for Women (NOW).  We are among the oldest and largest non-partisan women’s organizations in Virginia.  We are a membership organization of women and men with chapters across the Commonwealth, including: Alexandria, Arlington, Charlottesville, Fredericksburg, Hampton Roads, Montgomery County, NoVA (Fairfax County), Prince William County, Richmond, Rockbridge Valley, Vienna, and Yorktown. Our mission is to bring women into full participation in society, sharing equal rights with men and living free from discrimination. We promote awareness of issues that impact women economically, legally, socially, and personally. Our chapters work in their communities and cooperate at the state level to promote a feminist vision of a prosperous, thriving future for women and men in Virginia.

We are pleased that the Board of Health will review “targeted regulation of abortion providers” restrictions, commonly known at TRAP. We continue to be concerned about the negative impact of these burdensome, medically unnecessary regulations on women’s health and lives. They impose unnecessary difficulties for women to access safe, legal abortion services, which are essential to many women and their families. These excessive and costly regulations forced five Virginia women’s health centers to either shut their doors or stop providing abortion care before these regulations were amended in 2016.

Accessible, affordable, quality health care is essential to the well-being of women and our ability to care for our families. Thousands of Virginia women rely on Virginia women’s health centers for quality care, including services for sexually transmitted diseases, cancer screenings, birth control, and mammograms. Virginia NOW has worked consistently since our founding in1983 to improve the quality of life for all women, including ensuring that women’s clinics in the Commonwealth are safe and accessible.

All medical facilities, including abortion providers, are subject to a number of health and safety requirements, both at the federal and local levels. All medical facilities should be held to the highest safety standards, but most TRAP requirements do not protect patient health and safety. Some, for example, dictate the size of janitors’ closets and parking spaces. There is not – and never has been – a medically-justifiable reason for imposing hospital-style regulations on the Commonwealth’s safe outpatient women’s health centers. We are proud of the amendments adopted by the Board of Health during the last review of these regulations.  It is critical in light of the U.S. Supreme Court's 2016 Whole Women’s Health ruling that the Board implement additional commonsense and medically-based improvements.

Ensuring that health center regulations continue to reflect evidence-based medicine is the right step for protecting women’s access to health care and rolling back politically motivated attacks on access to health care. We are confident that the Board will once again put medicine above politics and promulgate regulations that are consistent with medical best-practices, adhere to legal guidelines, and protect access to health care for all women in Virginia.


Constance Cordovilla, President, Virginia NOW

7439 Patterson Road, Falls Church VA 22043








CommentID: 68664