Dear Board of Health Members,

I am writing to comment on Senate Bill 924, which requires facilities in which 5 or more first trimester abortions per month are performed to adhere to the same same Board of Health regulations as hospitals.  The regulations threaten the continued availability of safe, legal first-trimester abortion and preventive reproductive health care in multiple locations throughout the state.

The extensive, burdensome requirements for clinic buildings are unrelated to the services health centers provide, and have no proven medical benefit.  They will reduce or eliminate patient access to health care.
 
The regulations will increase the financial hurdles to health care for patients, with no proven medical benefit to patients. Women need more access to affordable, high quality health care, not less.
 
If regulations placed on women's health centers are based upon evidence-based medical practices that advance the public health, then women in the Commonwealth will be able to maintain access to vital health care from trusted medical providers.  If the regualtions are based upon evidence-based medical practices, they would and should apply to any facility performing five or more outpatient surgical procedures a month.
 
Medically inappropriate and unnecessarily burdensome regulations would restrict access to essential health care services for the women of Virginia and further marginalize young, low-income, uninsured and minority women by decreasing their health care options.

The high standard of care provided by women's health centers is proven by their impressive safety record. Abortion is one of the safest medical procedures. Overregulation will limit access to a wide range of preventive reproductive health care services provided by women's health clinics, including life-saving cancer screenings, family planning, and sexually transmitted infection testing and treatment. 
 
I recognize that you, the Board members, did not pass Senate Bill 924.  However, you will be responsible for developing and implementing the permanent regualtions.  It is my hope that the regulations will be amended to be based purely on medicine and science and should not impede women's access to essential health care.

Sincerely,

Jennifer Archer