|Action||Regulations for Licensure of Abortion Facilities|
|Comment Period||Ends 3/29/2013|
As healthcare professionals, we the undersigned want to lend our support to the Virginia Board of Health, and we thank the Board for all its efforts in promoting the health of Virginia’s citizens. As an independent agency, the Board has always acted with integrity and impartiality. Recently, however, political forces have challenged the independence of the Board. We appeal to the Board to resist these outside influences and urge the Board to make its decision on the basis of impartial, professional and scientific information as it relates to the women’s health clinic regulations. The reputation and credibility of the Board is at stake.
· Proposed Regulation 370, which addresses onerous and medically unnecessary architectural requirements, is clearly counter to the recommendations not only of the State-appointed group of respected university physicians but also the nationally-recognized Facility Guidelines Institute. These experts recommended that existing clinics be exempt from the new building regulations. This exemption is entirely consistent with previous Board of Health rulings covering other health care facilities. The Board made clear in 2006 that such rules would apply only to new construction. On June 15, 2012, the Board, following precedent, voted 7-4 to amend Regulation 370 based on the expert advice of the medical professionals.
· Although the purported intent of these regulations is to protect women’s health, the safety record of these clinics in the Commonwealth of Virginia has been exemplary.
· The Board of Health, not the Attorney General, has the statutory authority, as stated in the Virginia Code Ann: 32.1-127(A), to regulate health care facilities as long as they are “in substantial conformity to the standards of health, hygiene, sanitation, construction and safety as established by medical and health professionals and by specialists in matters of public health and safety.”
We all understand that abortion has supporters and detractors and we respect those views. The issue here is not and should not be about abortion. It is about the Virginia Board of Health as an independent, objective, public health advisory group that acts with impartiality in weighing scientific evidence.
We must not travel down a dangerous slippery slope where we allow political forces to dictate medical care.