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Regulations for Licensure of Abortion Facilities [REPEALED] [12 VAC 5 ‑ 412]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  7:00 am
Commenter: Kris Kennedy, MD, FACOG


To Whom It May Concern:                                                                              10/30/2018




I am writing today as an Virginia Ob/Gyn with over 30 years of experience. In the past I have asked the Virginia Board of Health to let evidence-based medicine and the advice of physicians guide the regulatory process regarding abortion providers. I am so grateful that you have complied.


Today I am writing again to request that we modernize our regulations. In the last few years medication induced abortion has become a standard of care throughout the world. There is strong evidence on the safety and efficacy of this procedure. Medication abortions should not be subjected to the same facility and procedure requirements as surgical abortions. I am requesting that you amend current regulations to allow safe dispensing of medications in physicians’ offices.


Allied health professionals such as Nurse Practitioners and Physician Assistants are well qualified to administer this medication under the supervision of a physician. I hope you will amend this regulation to allow for collaborative practice.


I hope we can agree that patient and provider safety and confidentiality must be a priority when revising regulations. Medication induced abortion still requires onerous paperwork in Virginia including a death certificate to the State. I personally have been harassed after having my confidentiality breached. As you can imagine, many physicians who are interested in providing this service to their own patients avoid doing so only because of this breach of confidentiality at the state level. It is time to eliminate this regulation requiring a Death Certificate for a medication abortion.


As you may be aware, many women are now purchasing these medications over the internet and administering at home without any local medical oversight. Placing burdensome restrictions on physicians will drive women to less safe alternatives. Please protect the safety of our citizens by eliminating unnecessary regulations.



Kris Kennedy, MD, FACOG



CommentID: 68569