URGENT Action Needed to Protect Women and Girls in Lancaster

Current regulation in Pennsylvania states that each freestanding Ambulatory Surgical Facility shall have a written agreement providing for patient access to routine emergency medical services at a hospital located within 30 minutes by ambulance of the facility. This includes 24/7 emergency physician services, full surgical or OB/GYN surgical capability, including anesthesia, blood bank, clinical laboratory and diagnostic radiological services. This is called a transfer agreement.

Planned Parenthood located on Manor Street in Lancaster has applied for an exception to this PA regulation which means these critical services would not be required for their facility to provide surgical or chemical abortions. This exception for Planned Parenthood would endanger the health, safety and welfare of women and girls receiving services at (onsite) and through this facility.

In Pennsylvania over 55 percent of abortions are now chemical. The abortion industry promotes “self-managed” abortions and “pills by mail” ignoring widely acknowledged health protections like medical screening, informed consent, and parental involvement for minors. The FDA ignores its own adverse event data that shows that the abortion pill has resulted in 26 deaths and thousands of serious complications by allowing neighborhood pharmacies to dispense the drugs without an in-person visit with a medical provider.

2023 is the 10-year anniversary of the conviction of Kermit Gosnell who conducted horrendously illegal practices in his Philadelphia “House of Horrors” abortion clinic highlighting the Pennsylvania health system’s abject failure to protect women’s health. The PA Department of Health should not abandon safety regulations vital to ensuring necessary protections for women’s health such as a transfer agreement to a hospital providing for emergency medical care by licensed medical professionals.

This is why we are asking you to submit comments to the PA Department of Health by email, fax, or mail to deny the exception to the transfer agreement being requested by Planned Parenthood. With four excellent hospitals in Lancaster, there is no reason for Planned Parenthood not to be required to provide this imperative health and safety measure required by PA regulation to pregnant women and girls.

Public Comments urging DENIAL of this exception must be received by the Department of Health before 5:00 p.m. on Tuesday, February 21.

Address Comments to Acting Secretary Bogen

Email: [email protected]

Fax: (717) 772-2163

Mail: Department of Health

Division of Acute and Ambulatory Care

Room 532, Health and Welfare Building

Harrisburg, PA 17120

(Please indicate if you are a resident of Lancaster County, medical professional, and/or parent in your comments.)

Top 20 Reasons to deny Planned Parenthood a transfer agreement exception.

Below are some points you may use from cited published research, peer-reviewed research, and public records in your comments to the Department of Health. Many are drawn from a fact sheet prepared by the Charlotte Lozier Institute (https://lozierinstitute.org/ )

The granting of Planned Parenthood Lancaster’s request for an exception to having a transfer agreement with a Lancaster hospital would endanger the health, safety, and/or welfare of women and girls in Lancaster. A transfer agreement is critical to provide timely and necessary emergency medical care given the risks and complications from abortion, particularly chemical abortion (also known as ”medication abortion”) through the use of mifepristone, also known as the abortion pill.

Published research shows … Chemical abortion has a complication rate four times that of surgical abortion, and as many as one out of five women will suffer a complication.[1] These risks only increase with advanced pregnancy and lack of medical supervision.[2]

Published research shows …. Three to seven out of every hundred women who choose chemical abortion early in pregnancy will need follow-up care to finish the abortion, with as many as 7-10% needing follow-up care for chemical abortions in the first trimester after 63 days of pregnancy and up to 39% requiring surgery if accidentally taken in second trimester.[1]
Published research shows …. As many as 15% of women will experience hemorrhage, and 2% will have an infection following chemical abortion. The risk of incomplete abortion and infection increases with increasing gestational age.[1]
Published research shows … Chemical abortion drugs are more likely to send women to the emergency room: the rate of chemical abortion-related emergency room visits increased over 500% between 2002-2015. [1,3]
Published research shows … Chemical abortions are over 50% more likely than surgical abortions to result in an ER visit within 30 days affecting one in twenty women.[1]
Published research shows …. that if a woman’s abortion pill-related complications are miscoded by emergency room personnel as a natural miscarriage, she is: twice as likely to be admitted for surgery for “retained products of conception”, and, she is significantly greater risk of multiple hospital admissions for treatment of the same complication.[4]
Published research shows … Mifepristone cannot treat an ectopic pregnancy and can mask the symptoms of tubal rupture, putting women at risk of severe bleeding and death. Approximately 2% of all pregnancies are ectopic.[1]
Published research shows … With no medical oversight, abortion pills can fall into the hands of traffickers and abusive partners. Already, there are accounts of women being given abortion pills without their knowledge and against their will. The risk of forced abortions will increase if the pills are available online without an in-person visit with the woman’s doctor.[1] In addition, a decrease in further access to care can elevate abuse situations by decreasing screening through emergent care. Sadly, the Lancaster area has been identified as having a high rate of sex trafficking placing victimized women and girls at higher risk forced abortion with its risks and complications.
Published research shows … The risks of chemical abortions aren’t just physical: women have described that their chemical abortion experiences left them feeling unprepared, silenced, regretful, or left with no other choice.[1]
Published research shows … A key analysis of abortion pill-related adverse events submitted to the FDA shows significant underreporting. Planned Parenthood independently reported over twice as many adverse events as the FDA in 2009-2010, despite the fact that FDA’s data is supposed to reflect complications from all abortion providers. FDA’s data is missing as many as 95% of all serious adverse events. Since 2016, the FDA no longer requires abortion providers to report any complications other than death.[1]
Published research shows … National abortion data is known to be incomplete, but there is enough data to show multiple deaths and thousands of serious complications resulting from chemical abortion. FDA’s own data shows that chemical abortion has resulted in at least 26 deaths and thousands of adverse events since the drug was first approved.[1]
Published research shows … Large-scale, peer-reviewed research studies in California, Finland, and Sweden show women are significantly more likely to experience serious complications after taking the abortion pill than after a surgical abortion.[5]
Published research shows … The safety of the abortion pill is clearly exaggerated. And this should be a wake-up call to all public health officials and our medical community here in Pennsylvania and Lancaster County.
Published research shows … The very real health risks for women and girls have only increased with self-managed abortion with pills arriving in the mailbox and women taking abortion pills at home.[2]
Published statistics from the Pennsylvania Department of Health show … from 2020 to 2021, chemical/”medication” abortions through the use of mifepristone, also known as the abortion pill, represented 55 percent of total abortions reported in Pennsylvania, up from 51 percent the previous year.[6]
Published records shows … In 2021, 9 of Pennsylvania’s 17 abortion facilities failed at least one inspection.[7]
Published research shows … Physicians who hold hospital privileges are significantly more likely to be board certified and to be approved for Medicaid payment than their colleagues without privileges.[8] A transfer agreement to an area hospital would assure a higher level of medical care for women and girls.
Published research shows … Left untreated, hemorrhage and infection from chemical abortion can place a woman’s or girl’s life at risk. Her future fertility may also be placed at risk.
Published records show … The abortion pill is approved for use on young girls, even though the FDA ignored its own rules by performing no studies focused on girls under the age of 18. The lack of scientific evidence leaves questions of how mifepristone (the abortion pill) may affect development and/or fertility of girls.
Overall, published research and public records … Compel us to speak up on behalf of women and girls in Lancaster. The granting of this request for an exemption would represent an abandonment of valid healthcare for women and girls.

Works Cited: