.

                                                                                                            January 31, 2012

Re: Proposed Regulations on Women’s Health Centers

Dear Members of the Board of Health:

 My name is Thomas H. Gresinger M.D., FACOG, and I am writing you concerning the Board’s development of permanent regulations for women’s health centers in the Commonwealth.  

 I request that the Board hold a public hearing in the next phase of the regulatory process. I also request that the Board appoint a regulatory advisory panel in order to supply professional and technical expertise to the Board.  I specifically request that experts in the area of gynecology, especially those who provide first trimester abortion care, be appointed to serve on this panel.

The Board of Health must seek and follow guidance regarding what is medically appropriate and in the interest of patient health for the regulation of women’s health centers, because the current temporary regulations are neither medically appropriate nor in the interest of patient health.

The sponsors of these regulations are the same ones who in all other matters claim that government has far too many troublesome and unnecessary regulations. One cannot but notice that similar facilities which surgically treat eye surgery, plastic surgery, orthopedic surgery, colonoscopy and others are not covered. But when the subject of abortion comes up, no holds barred.

The reality is that in the thirty nine years since Roe v. Wade first trimester abortion has become one of, if not the safest office procedure performed.

If these regulations are imposed, there will be some ill advised consequences:

            Some smaller facilities will be forced to close But some with higher patient volume                        and more resources will remain open at an unneeded great cost. The result of this will be                      that women in need of the service will be forced to travel farther and pay a much higher               price.

            The remaining facilities, having met hospital standards, will be able to go past the first                   trimester and perform late term abortions (as hospitals are now allowed). These                              procedures, as they get later and later, will result in more complications and the resulting                      admissions to local hospitals.

            The facilities forced to close will remove a much needed source of contraception,

            which reduces the abortion numbers, and cancer and STD screening.

            For reasons financial and logistical, some women will resort to illegal abortions,                             which, as those of us who practiced prior to 1973 can recall, resulted in the tragically                     large number of infected and/or perforated uterine complications, including the death of                        women, that resulted.

I am sure there would be more unintended consequences, but the above should be sufficient.

                                                            Sincerely,

                                                            Thomas H. Gresinger, M.D., FACOG