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]
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7/31/14  6:34 pm
Commenter: Margie Del Castillo, Virginia Latina Advocacy Network

Virginia Latina Advocacy TRAP Comment
 
The Virginia Latina Advocacy Network of the National Latina Institute for Reproductive Health respectfully asks that the Virginia Board of Health (“Board”) completely repeal and rewrite the current regulations of women’s health centers.  These regulations harm Latina health and impede a Latina’s ability to access the full range of reproductive healthcare.  Every Latina needs affordable and accessible pregnancy-related care, including abortion services, regardless of where she lives.
 
Current regulations of Virginia women’s health centers are about political interference in the personal decision-making ability of women.  Three years ago, the Virginia Department of Health convened a panel of six top medical experts from across the state to initially draft the regulations. Those experts recommended evidence-based regulations that protected women's health.  During the process of final decision-making by the Board in 2012, then Attorney General Cuccinelli pressured the Board behind the scenes, bullying them into approving restrictions designed to shut down women’s health centers.  Abortion providers must now meet building requirements designed for new hospitals - requirements that no other healthcare facility in Virginia must meet.  These regulations may impact over 640,000 Latinas/os in Virginia.  
 
Virginia’s regulations on women’s health centers create additional barriers to quality healthcare for Latinas.  These restrictions exacerbate current health inequities our communities face and contribute to negative health outcomes.  In 2011, 20% of Latinas/os were uninsured in Virginia.   Latina communities, including LGBTQ Latinas/os, suffer from disproportionately high rates of preventable and treatable reproductive health conditions.  Nationally, Latinas are diagnosed with cervical cancer at nearly twice the rate of non-Latina white women.   Latinas experience high rates of unintended pregnancy  and sexually transmitted infections including HIV .  Access, cost of care, and discrimination on the basis of sexual orientation and gender identity are among several attributing factors to these severe health outcomes.  In fact, 57% of young Latinas ages 18-34 have struggled with the cost of prescription contraception, making it highly likely that they will not be able to use contraception on a regular basis.   For many reasons, LGBTQ Latinas/os will need access to the full range of pregnancy-related care.  This community especially experiences high rates of sexual assault, “corrective rape,” unintended pregnancies, and lack of access to culturally and linguistically competent providers.  Women’s health centers may be the only facilities where low-income Latinas, including LGBTQ Latinas/os, can access the full range of reproductive healthcare they need when they need it.  
 
These regulations further delay and increase the cost of abortion care for low-income, Latinas.  Almost a quarter of Latinas live at or below the poverty level,  and over 40 percent of Latina headed family households live below the poverty level.   Approximately 69 percent of women obtaining abortion services live close to or below the federal poverty level and 27 percent of those women live in deep poverty, meaning that they have income at 100-199 percent of the federal poverty line.   A Latina working to raise the necessary funds for these services must often choose between paying for food, rent, or utilities, and the healthcare she needs.  Harmful restrictions such as mandatory counseling and waiting periods compound the cost for women due to lost wages and added childcare and transportation expenses.     If a Latina is unable to afford abortion care, she may be forced to carry her pregnancy to term.  Studies show that women who need abortion services but are denied care are three times more likely to fall into poverty than those who are able to receive the full range of pregnancy-related care.             
 
Finally, a majority of Virginians oppose these regulations.  Fifty-eight percent of Virginians oppose these regulations of women’s healthcare centers.   Moreover, restrictions on abortion services are out of step for what most Latinos/as think regarding political interference in Latina decision-making.  Seventy-four percent of registered Latino/a voters agree that a woman should be able to make her own personal, private decisions about abortion care without political interference.      
 
Access to reproductive healthcare, including abortion services, is a human right for Latinas.  Political interference in the personal, healthcare decisions of Latinas and their families deny them the ability to make the best decisions for their health with the consultation of their providers.    
 
The Virginia Latina Advocacy Network of the National Latina Institute for Reproductive Health urges the Board to completely repeal and rewrite the current regulations of women’s health centers.  
 
 
Sincerely,
 
Margie Del Castillo 
Field Coordinator-VA Latina Advocacy Network
National Latina Institute for Reproductive Health
 
CommentID: 35924