Virginia Regulatory Town Hall
Virginia Department of Health
State Board of Health
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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2/1/13  10:36 pm
Commenter: Stephen Vandivere

Oppoaw TRAP regulations

•  Women’s health centers will be forced 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.

If health centers manage to stay open, the cost of abortion procedures will rise so much that some women can no longer afford them.  VDH estimates that complying with TRAP laws may cost women’s health centers over $2.5 million.  This high cost could force health centers to pass the expense on to patients, making it impossible for women to afford and access the services they need. 

•  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. Grandfathering in of existing health centers should be restored to the proposed regulations.

•  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.

CommentID: 25512