Planned Parenthood Advocates of Virginia write to endorse the changes proposed in the public comments submitted by the Virginia Coalition to Protect Women’s Health.  Abortion providers in Virginia are already subjected to a plethora of regulations and standards, like any other similarly situated medical provider.  These regulations help ensure that women are afforded access to safe, high quality reproductive healthcare in the Commonwealth. Consequently, there is no need for additional regulations targeted at abortion providers . As the Virginia Board of Health conducts its current review of 12 Va. Admin. Code 5-412, we encourage the body to reduce administrative burdens that do not confer a medical benefit.  

While these targeted regulations are unnecessary as a general matter, they are particularly inappropriate for providers who do not perform any abortion procedures and simply prescribe medication abortion.  Medication abortion is an extremely safe method of ending a  pregnancy in the first trimester through the oral ingestion of two medications, mifepristone and misoprostol, and it is equally safe regardless of where the patient ingests the pills. Providers follow a regimen approved by the U.S. Food and Drug Administration (“FDA”). This regimen requires no anesthesia or sedation, and women can ingest the medications in the clinic or at home. Complications are extremely rare, and occur only after the patient has left the clinic. To put these complications in context, the rate of clinically significant adverse events from medication abortion is 0.16-0.31 percent, comparable to those of commonly prescribed antibiotics or even over-the-counter medications like Ibuprofen. Importantly, these rates are far lower than those associated with pregnancy and childbirth. 

Medication abortion is one of the major medical advances over the past two decades. It allows patients to end a pregnancy at home, without a procedure, surrounded by their chosen support network. Because it requires no sedation or specialized equipment, it allows more clinicians to provide early abortion care, thus increasing access and enabling patients to access care earlier in their pregnancy. This method is strongly preferred by many patients, and can be especially important to patients with a history of sexual or other physical trauma and patients with medical conditions (such as uterine fibroids) that can make medication abortion a safer option than aspiration abortion. 

This administration should be working to make medication abortion more accessible to patients, rather than perpetuating policies that make it harder to provide and receive this care. In particular, as part of this administrative review, we urge the Board to exempt medication-only providers from regulations governing the physical space in which care is provided and from other requirements similarly irrelevant to the safe provision of oral medications that can be taken at home. That would include regulations related to physical facilities, anesthesia services, examination of fetal tissue, and various irrelevant staffing, equipment, and emergency services requirements. See 12VAC-5, 5-214-40;12VAC5-412-50(C); 12VAC5-412-50(F); 12VAC5-412-70; 12VAC5-412-140(D); 12VAC5-412-160; 12VAC5-412-170;12VAC5-412-190 C; 12VAC5-412-220; 12VAC5-412-240; 12VAC5-412-250; 12VAC5-412-270 ; 12VAC5-412-280; 12VAC5-412-290;  12VAC5-412-370.

Thank you for your consideration.

Respectfully,

Missy Wesolowski 

Executive Director, Planned Parenthood Advocates of Virginia