Type over this text and enter your comments here. You are limited to approximately 3000 words

.13 February 2012

Re: Proposed Regulations on Women’s Health Centers

Dear Member of the Board of Health:

 I am writing regarding the Board’s development of permanent regulations for women’s health centers in the Commonwealth. I am a Women’s Health Nurse Practitioner with over 30 years experience in delivering health care to women in Virginia.  I request that the Board of Health Board hold a public hearing in the next phase of the regulatory process. I also request the Board appoint a regulatory advisory panel in order to supply professional and technical expertise to the board.  These persons appointed to serve on this panel should have expertise in women ‘s health including first trimester abortion and the economic impact on small businesses.

Currently there are several unintended consequences with the implementation of the proposed regulations.  Once a surgi- center is required by regulation for all abortion providers then many more, if not most, providers will start to provide 2^nd trimester procedures. Thus later, more costly and most important of all more dangerous procedures will become much more frequent and provided by most if not all the newly renovated centers. These later procedures will occur for several reasons: 1. The cost of abortion will go up, just as any health care provider, an office providing abortions must cover expenses and pay salaries; the cost of the renovations will be a factor driving up these costs, thus a woman of limited means seeking an abortion may have to wait several extra weeks while she gathers the necessary money pushing the procedure into a 2^nd trimester procedure. Most women deciding on an abortion will not change their ultimate plan only delay it.  2. Another factor is pure human nature, “if you build it, they will come”. Virginia could become a Mecca for 2^nd trimester abortions; the surgi centers that your new regulations require will be setting there waiting for patients, needing to re-coup the $100,000 or more spent in meeting your new regulations thus instead of sending patients out of state for these 2^nd trimester abortions the newly renovated centers have every reason to provide the services locally in Virginia. There is certainly a possibility that Virginia could become a referral center for 2^nd trimester abortions for neighboring states. My assumption is that the people who support these regulation changes did so to limit availability of abortion.  When one looks at the statistics from other states that have implemented similar regulation, one finds that the number of first trimester abortion did go down slightly, however the number of 2^nd trimester procedures went way up. Having experienced Women’s Health care providers on the advisory panel would help to prevent these unintended consequences.

Since most if not all businesses affected by regulations concerning major architectural renovations are usually “grandfathered” and there is no provision in these new regulations, a person familiar with economic impact to small businesses should be on the advisory panel.

  Who ever is ultimately appointed to the advisory panel should be experienced and should NOT have a political agenda. The Board of Health’s prestige and function is degredated by bowing to politics and personal “feelings” about any health issue. You have an obligation to make decisions using evidence based medical criteria not someone’s political agenda, or religious beliefs or just their feelings.

Again I would ask that during the regulatory process that you hold public hearings and appoint an advisory panel.  Thank you for your consideration in theses matters.

Sincerely,

Patricia L Crain, FNP/ WHNP