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  11:54 pm
Commenter: Roberta Dobbins

Board of Health's Proposed Regulations for Women's Health Centers
 

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I object to the temporary regulations for women’s health centers in Virginia and against the Board of Health’s proposed permanent regulations, which are identical to them.  I urge the Board of Health to restore citizens’ confidence by safeguarding women’s access to health services against partisan interference. 

The regulations:

  • threaten the availability of safe, legal first-trimester abortion and preventive reproductive health care throughout the state. This is unwarranted, because abortion is a legal and extremely safe procedure and the centers have an excellent safety record.
  • impose onerous architectural requirements that are inappropriate, have no proven medical effect, and are preventing patients from receiving essential medical care.
  • pose financial hurdles to patients without conferring benefit.  We must ensure equal access to health services for all citizens, regardless of sex, race, income, or residence.
  • undermine women’s health.  When the doors of these centers close, many women lose their only access to medical services like cancer screening, STD detection, and family planning.

In addition, I am very concerned that the temporary and proposed permanent regulations both fail to protect the confidentiality of health center and patient information. Apart from the usual privacy concerns, this could lead to serious abuse of this information with possible threats to the life and security of medical staff and patients.

The provision for surprise inspections and the removal of patient’s private information without notice are particularly intrusive and insensitive and could impact patient safety.  

I urge you to ensure that regulations placed on women’s health centers are based solely on medical evidence and on the principles of self-determination and equality in access to medical services. There must be mutual trust and respect between the citizens and the public health service.

CommentID: 23066