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Regulations for Licensure of Abortion Facilities [REPEALED] [12 VAC 5 ‑ 412]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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10/15/18  4:03 pm
Commenter: JWKerns, MD


I appreciate that you are reviewing these regulations, and do not envy that process.

My credentials, if needed, for comment are: working in primary care for 40 years in rural Virginia, research team member of a medical school, advanced research training, and teaching residents evidence-based medicine for over 20 years. (These views are NOT meant to in any way reflect the views of my department, residency, or practice). 

The evidence to support hospital-level regulations for abortion clinics is lacking. Conversely, the evidence that colonoscopy has a much higher rate of complications requiring hospitalization is well documented. Yet out-patient and office colonoscopies and similar procedures do not require a clinic with hospital access and other TARP regulations.

Please consider evidence as the primary driver as you ponder this emotionally charged issue.

Many thanks.

J. William Kerns, MD

CommentID: 67718