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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1/29/13  8:56 am
Commenter: Daniel Jason

Limit Abortion Center Regulation to Medically Justified Measures
 

Violations of safety standards at abortion centers, where they exist, are a very serious concern.  Requiring that every abortion center meet the construction standards of a hospital will not address that concern.  Safety violations can happen in shiny new buildings with specified water fountains, awnings and parking spaces, just as easily as they can happen in older ones.

if the concern is patient safety, the regulations should be limited to those that address patient safety.  Patient safety should not be used as a gateway to impose financial or politically-motivated sanctions on providers simply because they perform an unpopular (legal) procedure.

Similarly, it is absurd to make no distinction between providers who offer medication abortions and those who offer surgical abortions.  Under the proposed regulations, it appears that a provider who performs 5 or more medication abortions would be required to construct a surgical facility even if no surgery is ever performed.  That requirement is absurd on its face.  Providers who limit services to medication abortion, and do not perform surgery, should be required to maintain hospital affiliation agreements, not their own surgery centers.

Virginians are reasonable people who expect reasonable regulation.  Limit the regulations to those that promote health. 

CommentID: 25274