The rationale given by Commissioner Levine and VDH for eliminating policies and procedures for the screening of STDs from the abortion facility regulations was stated as follows: “The physician's regulatory advisory panel suggested the elimination of subsection A 3, as this provision is unrelated to abortion procedures.”

It is unfortunate that the panel of physicians advising the Health Commissioner, VDH and the Board of Health on abortion facility regulations is unaware of how STDs and abortion care are related.

·         The CDC understands that its guidelines “are applicable to any patient-care setting that serves persons at risk for STDs.” First in its list or patient-care settings are “family-planning clinics.” The CDC understands that “physicians and other health-care providers play a critical role in preventing and treating STDs.”

·         ACOG understands that “anyone who has had sexual contact with another person may get an STI. STIs may not cause symptoms. Even if there are no symptoms, your health can be affected.”

·         According to ACOG 2011 Women’s Health Facts and Stats, there are 19 million new STD cases each year, over 9 million in women ages 15-24. STDs are hard to diagnose, lead to serious health problems, and if not adequately treated, up to 40% of women can develop PID - a leading cause of ectopic pregnancy and infertility.

·         NAF’s Clinical Policy Guidelines recommend women who are at high risk for STIs be offered testing.

·         The CDC and ACOG recommend screening at annual visits for chlamydia, gonorrhea, HIV.

·         US Preventative Services Task Force agrees with almost all of the CDC’s recommendations for STD screening.

·         The Health Commissioner has developed “Virginia’s Plan for Well-Being.” One of the goals of the Plan is, “Cancers are prevented or diagnosed at the earliest stage possible,” with multiple strategies related to increasing cancer screenings. STD screening related to cervical cancer clearly helps with that goal.

Unmistakably the medical community understands the relationship between STDs and abortion, and sees a medical need for these kinds of services. Developing, implementing and maintaining policies and procedures related to the screening of STDs consistent with CDC Guidelines is good, quality healthcare clearly supported by medical best practices.

Furthermore, to be in compliance with existing regulations, all of VA’s abortion facilities must currently have policies and procedures for STD screening consistent with the CDC Guidelines. As far as we can tell, there have only ever been just two recorded instances of inspection violations regarding STD screening. We know of no other facilities have expressed any concern that complying with CDC Guidelines regarding STD screening to be too burdensome or medically unnecessary. There has been no confusion by these abortion facilities as to the relationship between STD screening and abortion. To remove implementation of CDC Guidelines regarding STD screening 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.” In fact, the health of patients would not be improved nor protected; the health and safety of patients and the community would suffer if there were no longer policies regarding STD screening.

During the September 2015 Board of Health meeting, there was discussion that “VDH does want patients to be assessed for risk and tested when appropriate but to be less prescriptive in the regulations about how that is accomplished.” The CDC Guidelines says they “should be regarded as a source of clinical guidance rather than prescriptive standards.” The CDC does not see their policy guidelines as prescriptive. Asking facilities to create and implement policies and procedures developed by the individual abortion facility is not prescriptive. Even so, Commissioner Levine and VDH offered no alternative, and recommended removing the requirement. If VDH understands STD screening to be appropriate, then an appropriate substitution should be given as an alternative instead of removing the requirement completely.

I highly recommend keeping the language as originally written, allowing for each facility to develop and maintain its own policies and procedures to ensure the “treatment of persons who have or are at risk for sexually transmitted diseases,” as stated in the CDC Guidelines.