I 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 chapter 12 Va. Admin. Code 5-412, I encourage the body to review this chapter closely and carefully consider which administrative burdens are actually beneficial in the context of 1) the safe outpatient procedures taking place in these facilities; and 2) the small patient and staff volume in many of these facilities, as compared to outpatient and inpatient surgical centers.  

Administrative Burdens

Many of the administrative burdens included in the regulations may be appropriate for large hospitals but are simply not appropriate for abortion providers, and ultimately have an adverse impact on patient care. While individually, any of these medically unnecessary regulations could be considered an inconvenience, taken together as a whole, they create a burden on providers and facilities.  As a result of these burdens, among other things, providers end up serving fewer patients.   

Some examples of current inappropriate administrative burdens that should be modified or eliminated include:

• 12VAC5-412-210. Quality Management.
• A “quality improvement committee” responsible for oversight and supervision of the required “ongoing, comprehensive, integrated, self-assessment program of the quality and appropriateness of care or services provided” may be useful for large hospitals with a large staff and multiple departments, but is unnecessary and inefficient for a small medical office. 
• 12VAC5-412-110. Plan of correction.
• The requirement that the plan of corrections show the expected correction date “not to exceed 30 working days from the exit date of the survey” is an unreasonable one given that abortion providers often do not receive an inspection report until well past that deadline or only within a few days of that deadline, if one is to understand the “end of the survey” to mean the date on which the actual inspection ended and not the date on which the abortion facility received the inspection report.

• 12VAC5-412-70. Return and/or reissuance of license.
• Requiring 30 days advance notice for voluntary closure or change of administrator is impracticable as these changes can happen quickly and should not require 30 days advance notice. 
• 12VAC5-412-180. Personnel.
• Abortion facilities and personnel have greater regulations regarding staffing decisions than those applicable to any other similarly situated medical provider and those regulations do not serve a medical benefit to patients. 

The Virginia Coalition to Protect Women’s Health proposes multiple changes in its public comments to correct the fundamental problems in this area; and we encourage the Board of Health to adopt them.  Removing unnecessary barriers to medical care is key to serving patients well.   

Thank you for your consideration.

Respectfully,

Laura Meyers

President and CEO, Planned Parenthood Metro Washington