Keep Women's Option for Post-Abortion Counseling

The rationale given by Commissioner Levine and VDH for removing “post-abortion counseling” from the abortion facility regulations was stated as follows: “The physician's regulatory advisory panel suggested the removal of ‘post-abortion counseling’ as the panel stated such counseling is not medically necessary and it's unclear what sort of counseling this would entail.”

It is unfortunate that the panel of physicians advising the Health Commissioner, VDH and the Board of Health on abortion facility regulations are unaware of the need for emotional healing that might need to take place after having an abortion. The National Abortion Federation’s own guidelines regarding “What Should I Expect After the Abortion?” clearly state the need to heal emotionally after having an abortion, and even states that it’s member clinics “provide post-abortion counseling or can provide you with referrals to pro-choice counseling services in your community if they do not,” offering multiple books and online resources to receive help. The nation’s largest abortion provider, Planned Parenthood, details post abortion counseling. They recognize how women "may feel anxious and have concerns about terminating [their] pregnancy” and that some women "do experience extreme negative reactions such as depression, shame, guilt, or regret." Clearly the abortion community is well aware of what constitutes “post-abortion counseling” and sees a medical need for these kinds of services.

Furthermore, to be in compliance with existing regulations, all of VA’s abortion facilities currently offer “post-abortion counseling.” To date, none of these facilities have ever been in non-compliance for failing to provide post-abortion services, nor have they expressed any concern of post-abortion counseling being too burdensome or medically unnecessary. There has been no confusion by these abortion facilities as to what constitutes “post-abortion counseling.” 

To remove “post-abortion counseling” from the regulations would not serve the Purpose of amending the abortion facility regulations as stated in the regulatory action documents…“Upon review, the Department of Health found areas of the regulations which could be improved, therefore protecting the health and safety of patients of these facilities to a higher degree.”

The health of patients would not be protected or improved by the removal of this requirement. Surely, they would be impacted for the worse if they were no longer offered post-abortion counseling. Therefore I recommend keeping the post-abortion counseling services in the abortion facility regulations.