Virginia Department of Health
State Board of Health
Regulations for Licensure of Abortion Facilities [REPEALED]
[12 VAC 5 ‑ 412]
Action | Regulations for Licensure of Abortion Facilities |
Stage | Proposed |
Comment Period | Ends 3/29/2013 |
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3/29/13 11:51 pm
Commenter:
Ann Covalt, consultant
Proposed TRAP regulations
Proposed TRAP regulations
Re proposed TRAP regulations on Virginia women’s health clinics
The Virginia Board of Health must not sign TRAP regulations, given the overwhelming evidence that doing so would violate the will of the majority, and the advice of numerous expert medical/health advisory bodies and professionals:
- Most Virginians oppose the proposed TRAP regulations for women’s health clinics in the state (http://prochoiceva.wordpress.com/2013/03/20/statewide-poll-shows-majority-of-virginians-oppose-trap/ ; the TRAP regulations, moreover, are highly arbitrary, burdensome, and costly, motivated by ideology, not science or concern for women’s health (http://www.medicinenotpolitics.com/Home_Page.html ; http://www.washingtonpost.com/opinions/mr-cuccinellis-abortion-crusade/2012/07/27/gJQAdv8mEX_story.html; http://www.coalitionforwomenshealth.org/learn-more/get-the-facts.shtml ).
- The affected health clinics provide reproductive health services, including first-trimester abortion and contraceptive counseling, to thousands of Virginia women a year, many who otherwise have no access to these services.
- As the above-cited statewide poll concluded, “Virginians see abortion as a private matter. By a wide three-to-one margin (75%-to-22%), Virginians agree “private medical decisions should be made by a woman, her family and her doctor” over “abortion is bigger than any single woman’s medical decision.”
- Women’s health clinics provide much more than abortion services – not only contraception counseling, testing for sexually transmitted diseases, and well-woman visits (breast and cervical cancer screening), among others. More than 90% of all American women use contraceptive coverage during their lifetimes; such coverage is especially critical to many lower income and more marginalized women who often lack information and other opportunities for quality medical services, but who can readily access these clinics throughout the state.
- Contraception is one of the most basic health care services to assure the health, and social and economic well-being of women and their families (and taxpayers), whether in Virginia, the United States, or worldwide, according to Institute of Medicine and Guttmacher Institute reports, among many others (http://www.iom.edu/Reports/2011/Clinical-Preventive-Services-for-Women-Closing-the-Gaps/Press-Release.aspx ; http://www.guttmacher.org/media/nr/2013/03/21/index.html
- Access to low-cost contraception lowers abortion rates (http://www.plannedparenthoodaction.org/elections-politics/newsroom/press-releases/new-contraceptive-study-proves-access-no-co-pay-birth-contro/ ).
Officials who promulgate TRAP regulations, or otherwise try to restrict women’s (and families') most needed healthcare services, are clearly not “conservative” in any sense, or even democratic in their action. It is an embarrassment, and more, a tragedy, that such officials would call themselves representatives of the people of our Commonwealth.
Ann Covalt
Arlington VA
CommentID: 27981