DHHS_medicaidAmericans United for Life submitted written comments today to the North Carolina Department of Health and Human Services (DHHS) on recently proposed rules for abortion facilities. AUL’s comments highlight the importance of such standards in protecting women’s health and safety and critique the rules as being deficient in several major respects.

Among the arguments AUL advances are that health and safety standards for abortion facilities are necessary for the protection of public health and safety for several reasons, including (a) abortion is an invasive surgical procedure that can lead to numerous and serious medical complications; and (b) even conservative estimates of abortion complication rates support the need for such standards.

For example, relying on the abortion industry’s own conservative estimates of complication rates along with the pro-abortion Guttmacher Institute’s latest report on induced abortions, in 2011 alone, more than 26,000 women experienced abortion-related complications, and more than 3,000 of these women required hospitalization. These numbers are not insignificant. Instead, they attest to a significant public health concern.

Deficiencies in the proposed North Carolina rules include that (a) in formulating proposed rules, DHHS failed to consult the Joint Commission (JCAHO) Standards for Ambulatory Care, the acknowledged “gold standards” for facilities performing outpatient surgical procedures; (b) DHHS is effectively and inappropriately delegating its regulatory and oversight authority to individual abortion facilities and has failed to adequately protect North Carolina women by mandating comprehensive, medically appropriate standards for such facilities; (c) the proposed rules do not provide for proper enforcement, inexplicably failing to prescribe criminal and/or civil penalties for violations; and (d) the proposed rules do not adequately define important terms, rendering the rules suspect and subject to varying interpretations.

Click here to read AUL’s comment.