|Action||Amend the Regulation after Assessment and Receipt of Public Comment|
|Comment Period||Ends 10/31/2018|
NOIRA TRAP Comment
W.K.G. & J, Incorporated
118 North Boulevard
Richmond, Virginia 23220
The Governing Authority for Richmond Medical Center for Women, Peninsula Medical Center for Women, and Roanoke Medical Center for Women
October 30, 2018
Dr. Norm Oliver and Members of the Board of Health:
Please take this opportunity amend the regulations for the licensure of abortion facilities, 12 VAC 5-412 to make them in line with evidence based medical practice.
We have been providing abortion care since 1973 and have experienced the extremely low complication rate that is a proven fact of abortion. The regulations as written, although improved since their inception, still stand as burdensome rather than helpful for providers or, more importantly, the women and their families who trust us with their care.
This nation’s leading medical associations recognize that TRAP regulations serve no
medical purpose. In fact, a recent National Academies of Science report found that these
regulations can cause real harm by reducing access and impacting providers’
ability to provide patient-centered care. Other studies confirm that abortions are as safe whether they are performed in an office setting or in a full ambulatory surgical center, so the TRAP statute and subsequent regulations at their very core are “not based on scientific evidence and don’t protect patient safety,” and therefore should be amended to reduce the duplicative burden imposed on abortion facilities.
We are not opposed to regulation of abortion facilities. We recognize that some regulation and oversight can make us better providers. One can feel that we make better partners – the department and providers – if the regulations were evidence based and geared toward truly improving safety and quality of care. The burdensome regulations and the castigatory nature of some of the inspections negates that.
Jill C. Abbey, President and Administrator