Action | Regulations for Licensure of Abortion Facilities |
Stage | Emergency/NOIRA |
Comment Period | Ended on 2/15/2012 |
New regulations to affect licensure of clinics that perform 5 or more first trimester abortions per month are not acceptable because of the unnecessary requirements (architectural changes, compromising of confidentiality), because of no evidence of need for the expanded regulations, because of the tremendous cost of establishing and implementing the unnecessary regulations, and because of the likely impact of reduced access to health care for Virginia women.
Nowhere.
Consider the costs incurred already.
How many hours did VDH personnel spend researching the regulations of over 22 other states? Did they spend time to find any applicable data about safety and complications or lack of reporting by the Virginia facilities?
How many hours did VDH personnel spend writing and re-writing the draft regulations?
How many hours did multiple members of staff in the office of the Attorney General spend analyzing the draft?
It is unconscionable to use taxpayer resources where there was no evidence gathered to indicate a need for the regulations.
Consider the subsequent VDH implementation costs:
Printing and distribution of documents.
Preparing new documents for inspection procedures.
Training of staff
Travel of staff for newly required inspections.
Record-keeping by staff on each clinic regarding compliance
Staff to gather data, enter data, report the data
Unknown: Costs to service women who will still need health care currently provided by these clinics
Consider how to measure the effect of the regulations:
Thus, there will be no way to make comparisons after the regulations are implemented.
Complying with unnecessary high-cost regulations that may diminish health care access for many low-income, uninsured, and underinsured Virginia will ultimately increase costs when the chance for early detection of diseases such as cancer is reduced.
Low-income women and rural women will have even less access to safe abortion care and family planning services. (It is harder for women and couples to access critical reproductive health care services, including life-saving cancer screenings, family planning, STI testing and treatment, and continued safe, legal abortion care.)
Consider better uses of funds and time: