Abortion center regulations are essential for the health and safety of Virginia women and must be maintained, not weakened.  The abortion industry has fought regulation for years, yet repeatedly independent inspectors find serious deficiencies, even during announced inspections. This is troubling.

Abortion centers are not able to self-regulate. Abortion is not healthcare, it ends lives instead of healing them. However, since abortion operates under the guise of healthcare, abortion centers must adhere to the regulatory standards of other healthcare facilities. Simply, Virginia women deserve nothing less.
I recommend the Board consider the following:

1. Reinstate all of the health and safety measures the Board watered down during its last amendment process. 
2. Require all Office of Licensure and Certification (OLC) inspections to verify that ultrasounds have been performed at least 24 hours prior to every abortion performed. 
3. Require annual inspections on abortion facilities instead of biennial. 
4. Remove the ability of the Commissioner to grant permanent variances.
5. Reinstate the definition of "first trimester" as being the first twelve weeks from conception, not "13 weeks and 6 days after last menstrual period." 
6. Reinstate the ability of the department to deny, suspend, or revoke the license to operate an abortion facility for violating "any provision of Article 1 (§ 32.1-123 et seq.) of Chapter 5 of Title 32.1."
7. Reinstate the requirement that the abortion facility ensures that it has removed all of the fetal body parts from inside of the female patient upon the performance of an abortion. 
8. Reinstate the requirement that abortion facilities report to OLC any incidents reported to the malpractice insurance carrier.
9. Reinstate the reasonable design and construction standards that provided for things such as hallways wide enough to carry patients out on stretchers in cases of emergency.

 Thank you for your consideration.  Please ensure the health and safety of all women.