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Regulations for Licensure of Abortion Facilities [REPEALED] [12 VAC 5 ‑ 412]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 Regulations for Licensure of Abortion Facilities
Stage Proposed
Comment Period Ends 3/29/2013
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2/15/13  11:52 am
Commenter: Joe Cook, Virginia representing 25,000 members

Scrap the TRAP Regs on Abortion Clinics

 As each of you know, the regulations in their present form have everything to do with a political and ideological agenda by Attorney General Cuccinelli, Governor McDonnel, certain members of the General Assembly and certain appointed members of the Board of Health to wage war on women and their right to control their own health care decisions. If approved as written, these burdensome and unnecessary regulations could force most women's health care centers in Virginia to close. This was the intended purpose to begin with, since they have an excellent record of safe and accessible care for women who, in many cases, have no other place to go for STD screenings, cancer screenings, family planning and safe and legal abortions.

Extensive, burdensome and expensive facility requirements meant for hospitals and unrelated to outpatient health care centers have no proven medical benefit and come from ideology, not science, and with the premeditated goal of forcing most of the centers to shut down. Women need more sources to access affordable, essential and quality health care, not less. Furthermore, the Board of Health exists to serve as the primary advocate of the residents of the Commonwealth for accessible, high quality patient care and the protection of public health, but these regs in their present form fail to do so.  A majority of the Board courageously amended Section 370 in June of last year in line with your mission but then reversed course under threats and coercion from the AG's office based on a flawed and tortured legal analysis. Now, I urge you as an independent body to return to your June position that was based on sound science and the best interests of the four million women in the Commonwealth.

The high standard of care at women's health clinics is proven by their safety record for all services provided, including abortions, which are available for the most part only at these centers. Use your independent judgement, trust women and stand up for them by amending the regulations again to reflect your June 2012 position based on science, not ideology or politics.

CommentID: 25962