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 Emergency/NOIRA
Comment Period Ended on 2/15/2012
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2/4/12  7:11 pm
Commenter: Kris Kennedy, MD

Facility restrictions for abortions
 


I am a Obstetrician/Gynecologist in Virginia Beach. I have been practicing here full time for 23 years. I am writing today to express my opposition to  the new restrictions on facilities performing abortions.

Over the last 10 years there has been a progressive push to perform minor surgical procedures in the office instead of an operating room. This shift saves a tremendous amount of money for the health care system and increases patient satisfaction. I perform procedures in my office today including endometrial ablations, hysteroscopy with D&C, and Essure tubal ligations. My office follows the In Office Procedure Safety Guidelines as published by the American College of Obstetrics and Gynecology. A first trimester abortion, whether spontaneous or elective fits well within the scope of procedures that would qualify for in office treatment.

I do not offer patients suffering from a miscarriage or women requesting an elective termination the option of an office procedure. I am unable to offer that service to my patients not because of safety or technical complexity of the procedure but because the  state of Virginia requirement that all patients have a death certificate completed. I can not risk the intrusion of the abortion debate into my office even for my patients suffering a miscarraige.

Insurance carriers reimburse us today for in office surgery as they have deemed it safe and cost effective.

If the government of Virginia has a primary concern for the safety of the women of Virginia then a review of all in office procedures would be more appropriate then a single assault on the woman requesting an elective termination.

Abortion whether spontaneous or elective can be performed  safely in an office setting with proper safety equipment and emergency back up. Please do not use patient safety as a cloak to further restrict women’s access to this vital service.

Thank you for your attention to this matter.

Sincerely,
CommentID: 21927