Agencies | Governor
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 Regulations for Licensure of Abortion Facilities
Stage Proposed
Comment Period Ends 3/29/2013
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1/28/13  9:14 am
Commenter: Lynn West

TRAP
 

Are you ready to face the consequences of this legislation?  We will head back to the days of back alley abortions as well as having more children born to women and girls who are unable to care for them.  If you can see past the religeous arguments ( which belong in churches, not in our government deliberations), look at this in practical terms and see what it will cost us all. 


1/28/13  9:18 am
Commenter: Emily Klinedinst

Make Public Comment and Speak Out Against TRAP!
 

 

The regulations threaten the continued availability of safe, legal first-trimester abortion and preventive reproductive health care in multiple locations throughout the state. 
 
Extensive, burdensome requirements for clinic buildings that are unrelated to the services health centers provide and have no proven medical benefit will reduce or eliminate patient access to health care.
 
The regulations will increase the financial hurdles to health care for patients, with no proven medical benefit to patients. Women need more access to affordable, high quality health care, not less.
 
If regulations placed on women's health centers are based upon evidence-based medical practices that advance the public health, then women in the Commonwealth will be able to maintain access to vital health care from trusted medical providers.
 
Medically inappropriate and unnecessarily burdensome regulations would restrict access to essential health care services for the women of Virginia and further marginalize young, low-income, uninsured and minority women by decreasing their health care options.
 
The high standard of care provided by women's health centers is proven by their impressive safety record. Abortion is one of the safest medical procedures. Overregulation will limit access to a wide range of preventive reproductive health care services provided by women's health clinics, including life-saving cancer screenings, family planning, and sexually transmitted infection testing and treatment. 
 
It is my hope that the regulations will be amended to be based purely on medicine and science and should not impede women's access to essential health care.

 


1/28/13  9:21 am
Commenter: Stephanie Ragusky

TRAP Regulations
 

 

To whom it concerns:

I am concerned at the ongoing efforts of a significant percentage of the VA legislature, the governor, and the attorney general, to limit women's access to medical care. I do not believe they are qualified to determine what is in a woman’s best interests in regards to decisions affecting her body, which is certainly demonstrated by unnecessary TRAP regulations.

The high standard of care provided by women’s health centers is proven by their safety record. There is no evidenced based reason for adding the unnecessary regulations promoted by TRAP. Abortion is one of the safest medical procedures. Overregulation will limit access to a wide range of preventive reproductive health care services provided by women’s health clinics, including life-saving cancer screenings, family planning, and sexually transmitted infection testing and treatment.

Trust women, respect choice.

Thank you for your time and attention.


1/28/13  9:24 am
Commenter: Catherine Smith

TRAP should be a no go
 

I am appalled that this type of regulation has even been put forward.  It is a huge step backward.  Women, especially lower income women need these critical services availabe to them at affordable costs.  Please do not allow this to happen.

 

Sincerely,

Catherine A. Smith 


1/28/13  9:25 am
Commenter: christi harris

TRAP regulations
 

My concerns with the TRAP regulations are many.  First, these regulations are not based on medical fact, but reflect the GOP's desire to do away with abortion in our country even though it is LEGAL and safe.  These desires stem from religious beliefs, which do nothing but compromise women's health care in Virginia.  Your righteous determination places burdensome restrictions on low-income, uninsured and minority women in this state who cannot afford time off of work, and cannot access transportation to the current one or two clinics that still exist in this state.  Even more importantly, abortion only makes up 3% of the services provided to women in these clinics.  When I was younger, and uninsured, I relied on these clinics for yearly checkups, cancer screenings, and birth control- which as a whole would eliminate the need for abortion.

Your efforts are misguided at best.  Instead of restricting access to abortion and health services, you should be concentrating on providing birth control and sex education which have been proven to drastically reduce the abortion rate.

I vehemently oppose the actions that our state government has taken in regards to women's health care.  Your moral objections are repugnant in consideration of the outcomes you provide for minority and low income women when you eliminate their choices.  Shame on all of you.

 

Sincerely

christi harris

 


1/28/13  9:30 am
Commenter: Alena Yarmosky

I STRONGLY oppose these harmful and medically-unnecessary proposed regulations
 

 

The regulations threaten the continued availability of safe, legal first-trimester abortion and preventive reproductive health care in multiple locations throughout the state.

Extensive, burdensome requirements for clinic buildings that are unrelated to the services health centers provide and have no proven medical benefit will reduce or eliminate patient access to health care.

The regulations will increase the financial hurdles to health care for patients, with no proven medical benefit to patients. Women need more access to affordable, high quality health care, not less.

If regulations placed on women's health centers are based upon evidence-based medical practices that advance the public health, then women in the Commonwealth will be able to maintain access to vital health care from trusted medical providers.

Medically inappropriate and unnecessarily burdensome regulations would restrict access to essential health care services for the women of Virginia and further marginalize young, low-income, uninsured and minority women by decreasing their health care options.

The high standard of care provided by women's health centers is proven by their impressive safety record. Abortion is one of the safest medical procedures. Overregulation will limit access to a wide range of preventive reproductive health care services provided by women's health clinics, including life-saving cancer screenings, family planning, and sexually transmitted infection testing and treatment.

It is my hope that the regulations will be amended to be based purely on medicine and science and should not impede women's access to essential health care.


1/28/13  9:35 am
Commenter: Evan Macbeth

Overturn TRAP Regulations
 

As a husband and father, I feel strongly that women's health is public health. Indeed, it is a truism that without healthy women, there wouldn't be any families. In my own life, I have seen women in my family whose best and only option for affordable, regular healthcare was a clinic provided in Virginia by Planned Parenthood. The TRAP bill would eliminate these critical links in the health services chain, and lead to an increasing risk of illness and disease among women whose only option for healthcare services was closed due to overly burdensome and totally unneessary regulation.

This General Assembly has marketed itself as being "friendly to business" and sought to reduce regulation. It is totally hypocritical, and wrong, to advance the TRAP bill to implementation while claiming to be against burdensome regulation. But more than that, it is bad for the health of women. And women's health is all of our health. Please change this bill and remove the burdensome and unnecessary requirements for clinics to be totally remodeled.


1/28/13  9:36 am
Commenter: Christine Ilich, Heirloom Kitchen

TRAP regulations are unnecessary
 


1/28/13  9:44 am
Commenter: robert j. cassell

oppose trap!
 

I am exstremely concerned by the unfair motivation behind trap laws. They are not designed to improve the health care for women. On the contrary the laws are a government over reach that will hurt a woman's access to local quality health care.


1/28/13  9:46 am
Commenter: yvonne royster

jyrdogs@gmail.com
 

Please do away with TARP. Women in Virginia do not want to go back to the dark ages of backroom abortions by butchers with coat hangers. Abortion access is the law of the land. Please respect our right to it accordingly!!!


1/28/13  9:53 am
Commenter: BT Birchett

Humanitarian: Oppose TRAP
 

 

To Whom It May Concern:

I strongly oppose these regulations to women's health care facilities here in Virginia.  These regulations are an obvious attempt at a political agenda, set our state back 50 years, and are simply illogical.  The regulations are not in any way based on medical fact, but reflect the new Tea-Party Republican attempts to force religious beliefs upon all of the people, which goes against the constitution which states that we are guaranteed our own religious beliefs (including the belief of when the soul enters the body).  These regulations, therefore, in reality only compromise women's health care in Virginia.  Should these regulation be put forth they would only restrict and add costs to low-income, uninsured and minority women in Virginia - ie. descrimination.  These women already cannot afford time off from work and have limited access to transportation and child support.  The clinics also supply women with cervical cancer screenings, keeping them well, safe, and stronger - the amount of abortions performed is a very, very low percent.  

Please do the right thing for our low-mid income women in this commonwealth - oppose these TRAP restrictions.  If we are truly concerned about abortion then why not take this effort and tax dollars to assist women with birth control and sex education which have a proven track record.

Again, I oppose these regulations, and would hope that you do the right thing an oppose them also.

Thank you for your time.


1/28/13  9:56 am
Commenter: Leslie Durr, PhD, RN, Private Citizen (Senior Female)

TRAP regulations
 

These regulations are a blatant ideological move - in point of fact, I can have oral surgery with anesthesia or invasive breast augmentation at outpatient surgery centers that are NOT required to have these regulations that are supposedly for a woman's health and safety.

Medically inappropriate and unnecessarily burdensome regulations will restrict access to essential health care services for the women of Virginia and further marginalize young, low-income, uninsured and minority women by decreasing their health care options. 

You are demonstrating your biases by including regulations not based on evidence but rather on ideology.


1/28/13  9:56 am
Commenter: David Scherer, citizen

TRAP
 

This is draconian politics!   Stupid & narrow-minded.

At least grandfather existing centers.


1/28/13  9:58 am
Commenter: Stacie Birchett

Please eliminate the medically inappropriate and unnecessarily burdensome TRAP regulations
 
I opposed the TRAP regulations as written. They threaten the continued availability of safe, legal first-trimester abortion and preventive reproductive health care in multiple locations throughout the state. 
 
Extensive, burdensome requirements for clinic buildings that are unrelated to the services health centers provide and have no proven medical benefit will reduce or eliminate patient access to health care.
 
The regulations will increase the financial hurdles to health care for patients, with no proven medical benefit to patients. Women need more access to affordable, high quality health care, not less.
 
If regulations placed on women's health centers are based upon evidence-based medical practices that advance the public health, then women in the Commonwealth will be able to maintain access to vital health care from trusted medical providers.
 
Medically inappropriate and unnecessarily burdensome regulations would restrict access to essential health care services for the women of Virginia and further marginalize young, low-income, uninsured and minority women by decreasing their health care options.
 
The high standard of care provided by women's health centers is proven by their impressive safety record. Abortion is one of the safest medical procedures. Overregulation will limit access to a wide range of preventive reproductive health care services provided by women's health clinics, including life-saving cancer screenings, family planning, and sexually transmitted infection testing and treatment. 
 
It is my hope that the regulations will be amended to be based purely on medicine and science and should not impede women's access to essential health care.

 


1/28/13  10:06 am
Commenter: Terrill Bailey, RN

TRAP
 

This legislation is meant to hurt clinics that only serve women. This needs to stop. As an RN I know that women's health is not something that needs to be this harshly regulated. Stop this attack on women's healt issues. This does not make government smaller, it makes it bigger and makes women a second class citizen. Stop this legistlation!


1/28/13  10:10 am
Commenter: Ezra Hitzeman, Citizen

TRAP
 

 

•  Women’s health centers will be forced to close because they cannot meet the new requirements.  TRAP laws require existing women’s health centers to come into compliance with three chapters of a manual called the 2010 Guidelines for Design and Construction of Health Care Facilities within the next two years. These Guidelines, however, are intended to apply only to new construction, not to existing facilities, which is how they are applied to every other health care facility in Virginia. Women’s health centers performing abortions should not be singled out.

• If health centers manage to stay open, the cost of abortion procedures will rise so much that some women can no longer afford them.  VDH estimates that complying with TRAP laws may cost women’s health centers over $2.5 million.  This high cost could force health centers to pass the expense on to patients, making it impossible for women to afford and access the services they need. 

•  TRAP laws will hurt women as well as men, restricting access to a wide range of preventive reproductive healthcare services, including life-saving cancer screenings, family planning and STI testing and treatment, as well as early abortion.

•  TRAP laws jeopardize the safety of abortion providers.  Abortion providers are often the targets of violence by anti-abortion extremists. The history of harassment and violence directed against professionals who provide abortion care makes it clear that confidentiality protections should be a part of the regulations to make sure that sensitive information can’t get into the wrong hands. But these draft regulations contain no such protections.

•  Loopholes leave patient confidentiality unprotected. Patients are targeted for harassment outside health centers and there is a history of anti-choice activists seeking patient information in order to deter women from obtaining care.  The regulations contain several loopholes that allow inspectors to remove patient records from the facility, rather than requiring them to examine the records onsite, and allow inspectors to request a list of all current patients. These regulations should be rejected so women’s health centers can continue to provide safe, accessible, comprehensive health care.

•  There are no legitimate medical purposes for singling out abortion providers. Extensive construction requirements have no relation to the safety of the services that women’s health centers provide. Regulating abortion differently than other outpatient procedures that are safely provided in non-hospital medical facilities is playing politics with women’s health.


1/28/13  10:11 am
Commenter: Jeff Carver

Board of Health, or Board of Right-Wing Politics?
 

Ladies and Gentlemen of the Board: This would be an excellent opportunity for you to decide whether your charter is to protect the health of the Commonwealth's citizens or to advance the political agenda of the right wing.


1/28/13  10:12 am
Commenter: Adrianna Venzor

Citizen against TRAP
 

Now that the public comment period is open, I feel deeply compelled to write to you and express my complete disgust for the unnecessary and burdensome TRAP regulations that are up for approval.  If approved, these regulations threaten the continued availability of safe, legal first-trimester abortions and preventetive reproductive health care in multiple locations throughout the state.  These regulations will also further marginalize young, low-income, uninsured, and minority women by decreasing their health care options.  

These regulations appear to be nothing more than a slight against women's health care and a way to force a pro-life agenda on the women of Virginia and I, for one, do not approve and I don't think I'm alone in this.

It is my hope that the regulations will be amended to be based purly on medicine and science and should not impede women's access to essential health care.  

Sincerely,

Adrianna Venzor


1/28/13  10:19 am
Commenter: Stacey Patmore

NO to TRAP
 

I am opposed to TRAP.  These unnecessary and burdensome regulations could force the majority of women’s health centers in Virginia to close their doors.  The regulations threaten the continued availability of safe, legal first-trimester abortion and preventive reproductive health care in multiple locations throughout the state.

 
Medically inappropriate and unnecessarily burdensome regulations would restrict access to essential health care services for the women of Virginia and further marginalize young, low-income, uninsured and minority women by decreasing their health care options.
 
The high standard of care provided by women's health centers is proven by their impressive safety record. Abortion is one of the safest medical procedures. Overregulation will limit access to a wide range of preventive reproductive health care services provided by women's health clinics, including life-saving cancer screenings, family planning, and sexually transmitted infection testing and treatment. 
 
It is my hope that the regulations will be amended to be based purely on medicine and science and should not impede women's access to essential health care.

 


1/28/13  10:22 am
Commenter: Jessie Barringer

TRAP
 

Targeted Regulations for Abortion Providers says it all. These regulations have nothing to do with women's health. They are meant to force abortion providers out of business. If they are implemented, they will severely restrict women's access to reproductive health care. 

Ms. Jessie Barringer, Broad Run, VA


1/28/13  10:26 am
Commenter: Abbey Fox

TRAP REGULATIONS
 

Dear Board of Health,

I write to you today to please consider acting against TRAP regulations. You are effectively circumventing a womans right to have an abortion.

 
The regulations threaten the continued availability of safe, legal first-trimester abortion and preventive reproductive health care in multiple locations throughout the state. 
 
Extensive, burdensome requirements for clinic buildings that are unrelated to the services health centers provide and have no proven medical benefit will reduce or eliminate patient access to health care.
 
The regulations will increase the financial hurdles to health care for patients, with no proven medical benefit to patients. Women need more access to affordable, high quality health care, not less.
 
If regulations placed on women's health centers are based upon evidence-based medical practices that advance the public health, then women in the Commonwealth will be able to maintain access to vital health care from trusted medical providers.
 
Medically inappropriate and unnecessarily burdensome regulations would restrict access to essential health care services for the women of Virginia and further marginalize young, low-income, uninsured and minority women by decreasing their health care options.
 
The high standard of care provided by women's health centers is proven by their impressive safety record. Abortion is one of the safest medical procedures. Overregulation will limit access to a wide range of preventive reproductive health care services provided by women's health clinics, including life-saving cancer screenings, family planning, and sexually transmitted infection testing and treatment. 
 
It is my hope that the regulations will be amended to be based purely on medicine and science and should not impede women's access to essential health care.
 
Thank you for your consideration,
 
Abbey Fox
Warrenton, VA

 

 

 

 


1/28/13  10:29 am
Commenter: Faith Anne Hurley

Oppose TRAP!
 

The Board of Health should make decisions to promote health based on sound medical and scientific knowledge, not a religious and political agenda to limit women's right to choose.


1/28/13  10:30 am
Commenter: H L Smith

Women's Health Centers
 

The regulations would cause the unnecessary closing of women's health care facilities. These facilities are already safe and provide necessary preventive reproductive health care to women.  Closing these facilitues would deny poor and middle class women access to health care. It would turn back the clock on women's equal rights to health care and create a slew of illegal back alley unregulated and fatal practitioners as we had prior to Roe V Wade. 

Keep in mind that the majority of the services offered are NOT abortion but are related to other reproductive care.  

This is a health issue not a moral or religious issue.


1/28/13  10:31 am
Commenter: Dr. Larry and Jeanette Heath

TRAP
 


1/28/13  10:39 am
Commenter: Kati Hornung

Regulatory changes for women's health clinics
 

 

It is my sincere hope that the regulations will be amended to reflect medicine and science and should not impede women's access to essential health care.  Particularly when this access is protected by the Supreme Court and divisive political agendas will simply waste taxpayer time and money before being overturned by the judiciary branch.
 
The high standard of care provided by women's health centers is proven by their impressive safety record. Abortion is one of the safest medical procedures. Overregulation will limit access to a wide range of preventive reproductive health care services provided by women's health clinics, including life-saving cancer screenings, family planning, and sexually transmitted infection testing and treatment.  At a minimum, please expand whatever decisions you are about to make for women's health clinics to ALL outpatient clinics.  If these are really concerns for safety they should be applicable across the board.  Particularly when you consider the number of adverse safety events for other out-patient procedures.
 
Let us get back to the business of good governance and leave the political ideology to those who seek the offices.  The Board of Health should not be involved in regulation that could be interpreted as illegal by the Supreme Court.  Please do not waste our attention, time, or resources any further.  
 
 

 

 

 


1/28/13  10:48 am
Commenter: Anna Holman

TRAP Laws
 

I am absolutely appalled by the TRAP Laws. These regulations are harmful to women, seek to restrict their personal freedom, and are completely partisan in nature. I am alarmed that the Virginia state government feel so entitled to control women's bodies that our legislators believe they have the authority to encroach on the personal liberties of Virginia women in such a direct, harmful way. These regulations are medically unnecessary, burdensome, and inappropriate. If our governmental officials were at all concerned with women's health, they would be able to see that these regulations will only harm women physically and psychologically. These regulations unfairly target low-income, uninsured, and minority women. However, the TRAP regulations are damaging for all women. TRAP directly infringes on my RIGHT to choice. TRAP directly obstructs my RIGHT to freedom and happiness. In case you have forgotten, Roe v. Wade did happen. Women's right to choose is a protected RIGHT in this country that prides itself on freedom and choice. It is my sincere hope that the Virginia State government will not put partisan and personal motives before the health of thousands of women. Repeal TRAP, save women's lives and health.


1/28/13  10:49 am
Commenter: ER Seidman

TRAP is BAD!
 

The TRAP laws are political in nature and not based on any medical needs. They are bad for women and bad for women's health. It jeopardizes access to safe abortions, a right that is guaranteed by law. Even if health centers meet the new requirements, it may well put the costs of abortions our of reach for many women. Maybe that is ultimately the reason for this law - to prevent or curtail abortions. Shame on Va Legislators, and especially the Attorney General Cuccinelli, for trying to imposed their own moral standards on the citizens of Va.


1/28/13  11:08 am
Commenter: David Drachsler

Abortion clinic regulations
 

•There are no legitimate medical purposes for singling out abortion providers. Extensive construction requirements have no relation to the safety of the services that women’s health centers provide. Regulating abortion differently than other outpatient procedures that are safely provided in non-hospital medical facilities is playing politics with women’s health.


1/28/13  11:14 am
Commenter: Margaret Knight

TRAP
 

The TRAP regulations are designed to place barriers to women's health care NOT protect them. For years these centers have provided SAFE essential services to women, especially women from low income families. The centers do NOT provide the medically invasive procedures that hospitals and other centers provide which require these architectural changes. These regulations are motivated by religiious and political ideology which has no place in health care decisions and regulations. Please protect all Virginian women and oppose these changes.


1/28/13  11:14 am
Commenter: Chris Baden-Mayer

Do Not Close Women's Health Centers
 

The proposed regulations for abortion providers are indeed "onerous and unnecessary". These new regulations would force the majority of women’s health centers in Virginia to close their doors.  Many Virginia women will have their personal health choices intruded upon and in many cases denied. Any state-required regulation should be based on medicine, not politics! The majority of women in the state of Virginia will oppose these regulations as an unecessary intrusion into a woman's personal health decisions. And speaking of politics, any elected official who supports this action will do so at their own political risk. You haven't taken away our right to vote! 

 


1/28/13  11:16 am
Commenter: Leslie Rubio/Women Untied

TRAP Laws
 

Attorney General Ken Cuccinelli insisted on over reaching his authority by demanding that Board Of Health members remove the grandfather clause from their recommendations to allow existing Women's clinics to remain open and not have to adhere to the newly imposed architechtural guidelines.  The Board of Health had previously made their decision to grandfather in existing clinics.  Their decision was based on public outcry and on testimony by doctors and medical professionals.  Ken Cuccinelli stripped the grandfather clause from the BOH's recommendations and pressured them to vote his way.  Since that overreach of power, Karen Remley, the Commissioner of the BOH, was forced to resign her position as she could no longer face the bullying by Ken Cuccinellit and his minions.

I was present at the first BOH meeting and offered my own opinion at that time.  I heard doctors, lawyers and medical professionals assert that these particular regulations were nothing more than an attempt to shut down abortion clinics.  In addition to abortion procedures, many of these women's clinics provide preventative care to underserved women who do not have access to health insurance or other medical care.  Why would the State of Virginia persecute the poor women of Virginia?  Why would the State of Virginia, who insists they are pro-business, want to shut down tax paying businesses? 

I listened to a urologist speak before the BOH and tell them about his practice.  He explained how many of the procedures in his office are far more invasive than an abortion procedure, yet he is not faced with strict guidelines at his practice.  The fact remains that these new restrictions are not about safety, they are about the moral and religious convictions of one man, Ken Cuccinelli, who has decided that his view will be the law of the land.  There have been no instances of emergencies or deaths stemming from unsafe practicies of abortion clinics in our State.

Ken Cuccinelli is wrong to bring more suffering to the women of Virginia.  Women in Virginia are capable of making our own choices about our own bodies.  We don't need the State or Federal government to do this for us.  If you really want to protect women, why not work on enforcing rape laws and providing women with the necessary tools they need to keep themselves safe from stalkers, rapists,  violence, and abuse.  Making abortion inaccessible to women DOES NOT make abortion go away, it only makes women less safe.

 


1/28/13  11:22 am
Commenter: Cherie Guerrant

TRAP
 

Please stop discriminating against women and passing unnecessary legislation that only affects women.  These laws infringe on women's rights.


1/28/13  11:23 am
Commenter: Tracey Lynch

women's reproductive rights and TRAP legislation
 

I have been a resident of the Commonwealth of Virginia for 12 years.  I have never been more afraid to be a woman in the Commonwealth than I am now.  The overlegislation of women’s reproductive rights based on one extreme religious perspective is the worst possible violation.  I have been subjected to the worst possible treatment by a member of the medical profession simply because I wanted to refill a medically necessary prescription for birth control.  This needs to stop now.

The high standard of care provided by women's health centers is proven by their impressive safety record. Abortion is one of the safest medical procedures. Overregulation will limit access to a wide range of preventive reproductive health care services provided by women's health clinics, including life-saving cancer screenings, family planning, and sexually transmitted infection testing and treatment. 

It is my hope that the regulations will be amended to be based purely on medicine and science and should not impede women's access to essential health care.


1/28/13  11:29 am
Commenter: Dorothy Laverdiere

TRAP
 
The TRAP regulationsas written  threaten the continued availability of safe, legal first-trimester abortion and preventive reproductive health care in multiple locations throughout the state. The regulations will increase the financial hurdles to health care for patients, with no proven medical benefit to patients. Women need more access to affordable, high quality health care, not less.
It is my hope that the regulations will be amended to be based purely on medicine and science and should not impede women's access to essential health care.

 


1/28/13  11:29 am
Commenter: Susan Klein

Keep Women's Health Centers Open
 

Women’s health centers will be forced to close because they cannot meet the new requirements.  TRAP laws require existing women’s health centers to come into compliance with three chapters of a manual called the 2010 Guidelines for Design and Construction of Health Care Facilities within the next two years. These Guidelines, however, are intended to apply only to new construction, not to existing facilities, which is how they are applied to every other health care facility in Virginia. Women’s health centers performing abortions should not be singled out.
 


1/28/13  11:32 am
Commenter: Richard Friend

Keep existing clinics open.
 

Please reconsder an grandfather in existing clinics , so women have options..


1/28/13  11:37 am
Commenter: Tucker Winter

TARP is HORRID!
 
The regulations threaten the continued availability of safe, legal first-trimester abortion and preventive reproductive health care in multiple locations throughout the state. 
 
Extensive, burdensome requirements for clinic buildings that are unrelated to the services health centers provide and have no proven medical benefit will reduce or eliminate patient access to health care.
 
The regulations will increase the financial hurdles to health care for patients, with no proven medical benefit to patients. Women need more access to affordable, high quality health care, not less.
 
If regulations placed on women's health centers are based upon evidence-based medical practices that advance the public health, then women in the Commonwealth will be able to maintain access to vital health care from trusted medical providers.
 
Medically inappropriate and unnecessarily burdensome regulations would restrict access to essential health care services for the women of Virginia and further marginalize young, low-income, uninsured and minority women by decreasing their health care options.
 
The high standard of care provided by women's health centers is proven by their impressive safety record. Abortion is one of the safest medical procedures. Overregulation will limit access to a wide range of preventive reproductive health care services provided by women's health clinics, including life-saving cancer screenings, family planning, and sexually transmitted infection testing and treatment. 
 
It is my hope that the regulations will be amended to be based purely on medicine and science and should not impede women's access to essential health care.

 


1/28/13  11:39 am
Commenter: Margy Ohring

TRAP
 

TRAP laws will hurt women as well as men, restricting access to a wide range of preventive reproductive healthcare services, including life-saving cancer screenings, family planning and STI testing and treatment, as well as early abortion.

There are no legitimate medical purposes for singling out abortion providers. Extensive construction requirements have no relation to the safety of the services that women’s health centers provide. Regulating abortion differently than other outpatient procedures that are safely provided in non-hospital medical facilities is playing politics with women’s health.


1/28/13  11:40 am
Commenter: Sandra Schott

Keep Politics Out of Medicine
 

Abortion is a legal procedure in the United States, and experts would agree it can be safely done on an outpatient basis.  The fact that some people have moral objections to the procedure should be of no concern to health department regulators.  Clearly, the attempt to impose architectural standards written for hospitals on existing abortion clinics is intended to limit access by those with moral objections to terminating pregnancies.  These standards are not essential to the performance of safe abotions and should not be applied to Virginia's abortion clinics. 


1/28/13  11:40 am
Commenter: Sherry Holland

Do we REALLY care about women's safety?
 

At one clinic in Falls Church: “dark reddish substance on the inner surface of the hub where the vacutainer tube for blood collection attached … Staff #8 was asked to observe the inner surface of each vacutainer he/she had designated as clean.  Staff #8 stated “That looks like blood.  They aren’t clean.”  At the same center, “An observation was conducted in Procedure room #1 at 11:16 a.m., with Staff #8.  Staff #8 reported the room was ready for the procedures scheduled for the day.  The observation revealed the procedure table had visible dried blood on the metal joints (Bilaterally) that connected the metal leg stirrup/supports.”

At the Alexandria abortion center: “On 7/19/12 the following observations were made: the attending physician was sitting at a desk reading the newspaper.  He put the paper away when the patient arrived.  The physician interviewed the patient.  The staff escorted the patient to the exam room.  The physician went into the room … The physician put on gloves and preceded to perform a vaginal ultrasound of the patient.  Once the procedure had been completed the physician told the patient to get dressed and he would see her outside the exam room … The physician picked up the patient’s medical record and began to make notations.  He removed a prescription pad from a drawer.  At no time was the physician observed washing his hands or performing hand hygiene.  The observations were pointed out to the physician who stated, ‘I was not doing a procedure only an ultrasound.  If I had been doing a procedure I certainly would have washed my hands.’  The above information was discussed with the administrator who stated, ‘He never washes his hands, he always uses gloves.’  When it was pointed out that sometimes the gloves may have holes in them the administrator stated, ‘Oh! That is gross!’”

At the Roanoke Medical Center for Women abortion center, the inspection reports found: “Staff used … a sponge to clean the procedure jars and failed to disinfect procedure jars and stoppers between patients … failure to disinfect three (3) of three recovery cots between patients and one (1) of one lab chair. ..observation revealed one of the vacutainer needle holders had visible dark red splatter within the hub, which attached to the needle to draw the patient’s blood.”

While focusing on the construction standards included in the health and safety standards, the media has almost completely ignored the blood stained and unsterilized equipment, along with all the other health and safety violations.  The construction standards are necessary to improve access for emergency personnel and equipment when medical emergencies take place, but the rest of the standards are basic to any medical facility that puts its patients ahead of its profits.  

With the discovery of dozens of health and safety violations through the initial announced inspections of abortion centers, the need for these standards have became even clearer.


1/28/13  11:44 am
Commenter: W. R. Knight

Restrictions on Women's Health Centers
 

The first amendment to the U.S. Constitution protects its citizens from state sponsored religion.  It also prohibits the government from enforcing or imposing religious beliefs or worship on its citizens.  The fourteenth amendment to the U.S. Constitution extends that protection to all the States.

Rules and laws regulating the operation of any health organization must be based strictly on medical, scientific and public safety and welfare considerations only.  Religious beliefs have no place in the enactment of laws regulating health organizations of any kind.

America is NOT a Christian nation.  It is a secular nation in which all religions are created equal and may be practiced freely or not at all by each and every American.  Don't ever forget that.

 


1/28/13  11:46 am
Commenter: Jane Fuller

Safety Regulations for Abortion Clinics
 

I appreciate the efforts of our legislators to ensure the safety standards for abortion clinics in VA meet the same that are required of our out-patient surgerical centers.  Women' deserve better than what is being allowed in Falls Church, Alexandria and other clinics that showed uncorrected deficiencies. 

Abortion is a big money and powerful business.  It is a vital role of our Government to protect citizens from businesses that put the bottom line ahead of safety and walfare.


1/28/13  11:48 am
Commenter: Hilary Eckberg

Please oppose TRAP laws
 

I urge the Board of Health to oppose TRAP laws.  Women's health centers may be forced to close thier doors if they cannot meet the new requirements of TRAP, and even if they are able to stay open, the cost of services will rise so much that ultimately they may not be able to serve the populations that need them so desperately.  Women's health centers help a wide range of people with everything from safe and legal abortions to cancer and STI screenings and family planning.

Furthermore, some of the rules in the TRAP laws leave patients who have visited these facilities exposed.  The regulations contain several loopholes that allow inspectors to remove patient records from the facility, rather than requiring them to review the records onsite, and to request list of patients.  The patients who visit women's health centers deserve as much privacy and respect as any other patient. 

There is no legitimate reason for singlin out abortion providers.  So please oppose these unnecessary restrictions.

Thank you. 


1/28/13  11:49 am
Commenter: Laura Bucklin

OPPOSE TRAP
 

I strongly oppose the TRAP legislation that is being pushed through by far-right ideologues.  I don;t buy the excuse that the regulations will make it safer for women - for if safety is at the core of their intents....why then not make ALL medical practices who do outpatient surgery comply with the proposed regulations? 

If you don't like abortion, do not have one.  Plain and simple. 

I oppose these regulations and expect the board to vote on them with reason, instead of a far-right political agenda and the lie that they are overly concerned with safety for women.  For if THAT is the case, it would sure be nice to see them try and make sure the maternal and infant death rate in VA be brought to ZERO. 


1/28/13  11:54 am
Commenter: Ronald Wilson

Abortion Center Health Safty Regulations
 

The argument for abortion has always been to keep it safe for women. It is hard for me to believe that anyone would not want the same health safty regulations in an abortion clinic as in any other medical clinic. It's just good medical practice and common sense to support abortion center health safty regulations. So, I am writing to support the abortion center health safty regulations.


1/28/13  11:54 am
Commenter: Kimberly Jones Clark

Women's healthcare.
 

I beg of you....do NOT take these essential health care options and facilities away from my daughter, your daughters, your granddaughters.  They deserve to have the safest and most informative care available.  Do you REALLY want to take us down to the level of a third world country?  Do you REALLY want to embarrass yourselves... your board by allowing this disgraceful legislation to pass? I urge you to think long and hard about the consequences of your actions. Let's rise up to a status of dignity and respect by providing top notch care for ALL citizens.

Thank you.


1/28/13  11:58 am
Commenter: Harry Baird

Abortion Facilities Health Regulations
 

Why should abortion clinics be favored over other health provider facilities when it comes to proper health standards?  Would you like to go into a doctor's office or hospital, and not have the benefit of health regulations?  I strongly support that the same stringent standards required of doctors and hospitals be applied to abortion facilities.


1/28/13  12:02 pm
Commenter: Maggie Ciskanik, RN, MS

Health and safety for women?
 

If this state is serious about the health and safety of women who choose to have abortions, supporting the proposed legislation will offer at least the minimum level of compliance by abortion providers.  Why should abortion clinics be less accountable than other health facilities?

Framing support of the legislation as ideologically driven is as equally applicable to those who oppose it.  It is tiring to hear the rhetoric hurled in what should be an open and honest debate.

 


1/28/13  12:05 pm
Commenter: Barbara Null

Regulations for Licensure of Abortion Facilities [Under Development] [12 VAC 5 ? 412]
 

 

There are no legitimate medical purposes for singling out abortion providers. Extensive construction requirements have no relation to the safety of the services that women’s health centers provide. Regulating abortion differently than other outpatient procedures that are safely provided in non-hospital medical facilities is playing politics with women’s health.