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]
Action Regulations for Licensure of Abortion Facilities
Stage Proposed
Comment Period Ended on 3/29/2013
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1/28/13  3:27 pm
Commenter: Kathleen McLane

TRAP is nothing but a Trap.
 

It is the opinion of many, including many physicians, that these new rules are not necessary, yet Governor McDonell and Attorney General Cucinelli continue to persue and place presure for these rules. There are no legitimate medical purposes for singling out abortion providers. Extensive construction requirements have no relation to the safety of the services that women’s health centers provide. Regulating abortion differently than other outpatient procedures that are safely provided in non-hospital medical facilities is playing politics with women’s health. But that is the entire point, isn't it? Imposing the Governor and Attorney General's views on the Commonwealth of Virginia despite the unpopularity of these actions even in the face of the fact that many women will go wanting for other health related reasons. The entire point of these regualations is to force Women’s health centers to close because they cannot meet the new requirements. TRAP laws require existing women’s health centers to come into compliance with three chapters of a manual called the 2010 Guidelines for Design and Construction of Health Care Facilities within the next two years. These Guidelines, however, are intended to apply only to new construction, not to existing facilities, which is how they are applied to every other health care facility in Virginia. Women’s health centers performing abortions should not be singled out. Please consider that if TRAP is forced on Virginia's citizens that

•  TRAP laws will hurt women as well as men, restricting access to a wide range of preventive reproductive healthcare services, including life-saving cancer screenings, family planning and STI testing and treatment, as well as early abortion.

•  TRAP laws jeopardize the safety of abortion providers.  Abortion providers are often the targets of violence by anti-abortion extremists. The history of harassment and violence directed against professionals who provide abortion care makes it clear that confidentiality protections should be a part of the regulations to make sure that sensitive information can’t get into the wrong hands. But these draft regulations contain no such protections.

•  Loopholes leave patient confidentiality unprotected. Patients are targeted for harassment outside health centers and there is a history of anti-choice activists seeking patient information in order to deter women from obtaining care.  The regulations contain several loopholes that allow inspectors to remove patient records from the facility, rather than requiring them to examine the records onsite, and allow inspectors to request a list of all current patients. These regulations should be rejected so women’s health centers can continue to provide safe, accessible, comprehensive health care.

 

CommentID: 25002