Dear ProLife Doctor, You know AAPLOG stands against abortion. In addition, as medical doctors, we stand against substandard treatment of women in general. One of the most flagrant examples of substandard medical treatment is often found in unregulated abortion clinics. The Maryland Dept Health and Mental Hygiene is working to draft regulations for surgical abortion facilities. They need your input by Aug 19. You can do this. And if not you, who will?? They need your comments in 3 specific areas, as outlined below. And there is a link to the entire draft, if you wish to read the whole thing. If you Maryland doctors do not comment, who will?? We urge you to see below, and do what you can. It will not demand much time. Maryland women need you now. 1. All abortions must be done in properly equipped facility. 2. Sonograms are essential to determine gestational age, and rule out ectopic pregnancies, and this shall be part of the medical record. 3. The record shall be complete, as is required by any ambulatory surgical facility. Actually that is about all you have to write. Comments are due by Aug. 19th, and can be sent to regs@dhmh.state.md.us Obviously, in public comment, Maryland medical doctors comments will weigh very heavily. (Any Maryland resident should comment) Please do your part. Full letter and email address is below: Dear Maryland members of AAPLOG, The Maryland Catholic Conference and several other pro-life groups have been working for years to have Maryland’s abortion clinics regulated by the Office of Health Care Quality. Currently they are not regulated as surgical facilities since they fall outside the definition of ambulatory surgical facilities, and there have been an inordinate number of maternal deaths and injuries because of this. Our efforts have finally yielded some results — the Department of Health and Mental Hygiene (DHMH) published draft regulations for surgical abortion facilities last week and is requesting public comments. We think the regulations are very good because they are based on the existing regulations that govern ambulatory surgical facilities. There are only a few places where the proposed regulations differ substantially from the ambulatory surgical facility regulations. 1) We are concerned that the regulations are not going to apply to every facility where surgical abortions are done. They will only apply to facilities where abortions are done “on a routine basis.” Especially in light of the fact that the physician who only performs abortions occasionally is more likely to cause an injury, due to lack of experience with the procedure, it makes sense to require that all abortions be done at a facility that is properly equipped to do them safely. Because of the very large number of injuries and deaths that have occurred in Maryland abortion clinics, we don’t think DHMH should allow physicians to do abortions in an office setting. Page 2, the definition section of the regulations, is where they try to define which types of facilities will be subject to the regulations, and we have concerns about how the phrase “on a routine basis” will be interpreted. 2) We noticed that the ambulatory surgical facility regulations include a section on “Laboratory and Radiologic Services,” but in the abortion clinic regulations the references to “radiologic services” have been removed (see section 12 on page 12). Sonograms are important for making sure the abortion was complete, for determining the gestational age of the fetus, and for ruling out an ectopic pregnancy. The ambulatory surgical facility regulations read as follows, and we think “radiologic services” should appear in the same places in the abortion clinic regulations : “Laboratory and Radiologic Services. A. The administrator shall develop and implement policies and procedures for obtaining routine and emergency laboratory and radiologic services to meet the needs of patients. Policies and procedures shall include: (1) Turn-around time; (2) Review of laboratory reports; and (3) Documentation of laboratory results. B. Laboratory facilities shall be approved under the Clinical Laboratory Improvement Act (CLIA) and be licensed by this State. C. The freestanding ambulatory surgical facility shall include laboratory and radiologic reports in the patient’s medical records.” 3) Another section that is concerning is section 10.12.01.13, “Medical Records,” page 12. The corresponding section of the ambulatory surgical facility regulations includes the following: “Each medical record shall include, at a minimum: (1) Preoperative diagnostic studies, entered before surgery, if performed; (2) Findings and techniques of the operation, including a pathologist’s report on all tissues removed during surgery, except those tissues exempted by the medical director; (3) any allergies and abnormal drug reactions; and (4) entries related to anesthesia administration.” This section is not included in the abortion clinic regulations. Especially in an early abortion there is a great need to demonstrate that the fetus is not in a fallopian tube, so sending the uterine contents for pathology is important. At the very least, there should be a section in the regulations specifying that appropriate steps must be taken to rule out an ectopic pregnancy. Would you be willing to send some comments to DHMH, addressing one or more of the areas for which we feel the proposed regulations are insufficient, and any other areas you identify? Your input as an OB-GYN would be given serious consideration by DHMH, much more so than input from an average citizen. Here’s a link to the DHMH web page that contains links to a Q&A document and the proposed regulations: http://www.dhmh.md.gov/health/draftregs.html Comments are due by Aug. 19th, and can be sent to regs@dhmh.state.md.us . DHMH is requesting that comments include the specific section of the regs and the comments related to it. If you have time to send a few sentences it would be very helpful, and I thank you in advance. Sincerely, Nancy Paltell, Maryland Catholic Conference, 410-269-1155
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