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 Amend Regulations Following Periodic Review
Stage Proposed
Comment Period Ended on 7/1/2016
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6/30/16  11:35 pm
Commenter: Stephanie Harlow

CDC, ACOG, NAF, VDH Recommend STD Screening as Part of Clinical Encounter
 

The CDC, ACOG, NAF, even the state of Virginia recommend STD screenings for sexually active women. We should not remove this evidence-based healthcare from the abortion regulations.

The CDC's 2015 Sexually Transmitted Diseases Treatment Guidelines state, "Primary prevention of STDs includes performing an assessment of behavioral risk (i.e., assessing the sexual behaviors that may place persons at risk for infection) as well as biologic risk (i.e., testing for risk markers for HIV acquisition or transmission). As part of the clinical encounter, health-care providers should routinely obtain sexual histories from their patients and address risk reduction as indicated in this report." 

"In addition to obtaining a behavioral risk assessment, a comprehensive STD/HIV risk assessment should include STD screening." 

ACOG's 2011 Women's Health Stats & Facts lists recommmendations of screening: 

- "ACOG recommends annual screening for chlamydia of all sexually active women ages 25 and younger, as well as annual screening of other asymptomatic women at high risk for infection."

- "ACOG recommends annual screening for gonorrhea of all sexually active women ages 25 and younger, as well as other asymptomatic women at high risk for infection."

- "ACOG recommends routine HIV screening for all women ages 19–64, regardless of their individual risk factors."

NAF's 2016 Clinical Policy Guidelines states, "Women at high risk for Chlamydia, gonorrhea, or other sexually transmitted infections should be offered testing."

The Health Commissioner's 2016-2020 Virginia Plan for Well-Being lists as Foundational Goals for AIM 3: Preventive Actions, "Virginians are free from sexually transmitted infections" and "In Virginia, cancers are prevented or diagnosed at the earliest stage possible."

Abortion facilities might be the only place a woman is seen by a licensed healthcare professional. How can Virginia be free from STI's when it has removed the medically-appropriate requirement from abortion facilities to include STI screening? 

The Commissioner and VDH should not remove 12VAC5-412-240.3, "The abortion facility shall develop, implement, and maintain policies and procedures for screening of sexually transmitted diseases consistent with current guidelines issued by the U.S. Centers for Disease Control and Prevention. The policies and procedures shall address appropriate responses to a positive screening test."

CommentID: 50501