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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2/15/12  11:07 am
Commenter: Caroline Flournoy

Targeted Regulation of Abortion Providers: Please don't go there.
 

As a Virginia native, as a woman, as a human being: my disappointment with the recent Board of Health regulations on providers of abortion in Virginia is bottomless. There is no medical reason to impose these regulations, designed for hospitals, on outpatient clinics; the regulations have no direct bearing on patient care. They would, however, put all current abortion providers out of operation in Virginia.

Virginia women will still seek abortions under the proposed regulatory scheme. Women who can find the means to reach DC or Maryland will get abortions anyway, but at greater expense and quite likely later in pregnancy than they would if abortion remains obtainable in Virginia. Imposing greater expense, emotional costs, and more-advanced fetal development on Virginia women seeking a procedure that is still legal in all 50 states, far from advancing the health and safety of Virginians, actively undermines the goals of providing safe, well-regulated legally available medical care to all Virginians. Even more worryingly, women unable to undertake a trip out of state may seek unregulated abortions locally.

Far from claiming that abortion providers shouldn't be subject to regulation, I worry most of all about the Virginia women who, out of poverty, desperation, or ignorance will seek unregulated abortions if reputable, safe abortion clinics are forced to close. In 2011, unregulated, abusive and illegal practices in clinics in Pennsylvania, Illinois, and Florida made the national news. It's clear that, like providers of any other medical service, abortion providers must be subject to regulation and sanctions for violating good practice.

The proposed regulations in Virginia, however, are not the good regulations we need: they would do nothing to improve patient safety (Virginia abortion providers already have a good record in this regard); in fact, they would almost certainly undermine patient safety by raising the bar to obtaining abortion services, driving women to seek later abortions out of state or to seek unregulated abortions in-state. We don't need to give individuals like Kermit Gosnell a market performing questionable abortions on desperate women.

Please reconsider the proposed regulations. Please re-align the goals of the Virginia Board of Health with women's health, safety, and well-being. Let the Governor fail to sleep at night if abortion bothers him so much. It isn't his body on the line - some of us have far more at stake than the kind of conscience that can be assuaged by this shameful attempt to bypass the democratic process and impose a virtual ban on abortion in Virginia by executive fiat.

CommentID: 22792