New regulations to affect licensure of clinics that perform 5 or more first trimester abortions per month are not  acceptable because of the unnecessary requirements (architectural changes, compromising of confidentiality), because of no evidence of need for the expanded regulations, because of the tremendous cost of establishing and implementing the unnecessary regulations, and because of the likely impact of reduced access to health care for Virginia women.

 (Support, not obstacles, is needed for health care of Virginia women.)

 Where is there any VDH data that indicates any evidence of safety concerns or complications from abortion procedures in these clinics?

Nowhere.

 Consider the tremendous costs:

Consider the costs incurred already.

How many hours did VDH personnel spend researching the regulations of over 22 other states? Did they spend time to find any applicable data about safety and complications or lack of reporting by the Virginia facilities?

How many hours did VDH personnel spend writing and re-writing the draft regulations?

How many hours did multiple members of staff in the office of the Attorney General spend analyzing the draft?

It is unconscionable to use taxpayer resources where there was no evidence gathered to indicate a need for the regulations.

For what? To produce a booklet of  unnecessary regulations?

Consider the subsequent VDH implementation costs:

Printing and distribution of documents.

Preparing new documents for inspection procedures.

Training of staff

Travel of staff for newly required inspections.

Record-keeping by staff on each clinic regarding compliance

Staff to gather data, enter data, report the data

Unknown: Costs to service women who will still need health care currently provided by these clinics

 Consider the concerns about compliance of VDH with confidentiality:

 With great difficulty in acceptance of consideration of amendments at the BOH hearing regarding protection of confidentiality at abortion clinics there is excessive doubt remaining for adequate confidentiality measures.

Consider how to measure the effect of the regulations:

Given that there was no baseline data before the regulations were written there is no way to measure the effect. At the BOH hearing VDH personnel presented information on the drop in the rate of infant mortality in Virginia but there was no data to determine any rates of complications from abortion procedures in Virginia, so apparently there have been no complications to report.

Thus, there will be no way to make comparisons after the regulations are implemented.

 This is a major deficiency in how these regulations were initiated.

 MOSTLY/PRIMARILY:

 Consider the costs to the good health of women in Virginia:

Complying with unnecessary high-cost regulations that may diminish health care access for many low-income, uninsured, and underinsured Virginia will ultimately increase costs when the chance for early detection of diseases such as cancer is reduced.

Low-income women and rural women will have even less access to safe abortion care and family planning services. (It is harder for women and couples to access critical reproductive health care services, including life-saving cancer screenings, family planning, STI testing and treatment, and continued safe, legal abortion care.)

 FAR MORE IMPORTANT ACTION:

Consider better uses of funds and time:

 Provide funds for prevention of  unwanted pregnancies instead of using funds for time, travel, and reporting of inspections of abortion clinics. There ARE life situations where the unexpected happens.

 Provide funds for subsidizing education programs and facilities to increase health care education and providers at all levels. Increase the supply of Nurse Practitioners, Physician’s Assistants, and Midwives.

 Provide increased funding for Social Service agencies throughout the Commonwealth.