RESOURCE FOR COMMENTS TO THE NJ BOARDS OF MEDICAL EXAMINERS

RESOURCE FOR COMMENTS TO THE NJ BOARD OF MEDICAL EXAMINERS

Margarita Sori, Ph.D.                                                                   January 28, 2021

                                                        BACKGROUND

The NJ Board of Medical Examiners sets rules for the licensing of medical professionals – physicians, nurses, midwives, physician assistants, podiatrists, and lab directors. It issues licenses, handles complaints against the licensed medical professionals, and takes disciplinary actions such as temporarily or permanently revoking licenses.

Currently only licensed physicians can perform abortions in NJ. Restrictions on them are few. The rule changes being proposed by the NJ Board of Medical Examiners would license Advanced Practice Nurses, Physician Assistants, Certified Nurse Midwives, and Certified Midwives to perform abortions.

Since some of these medical professionals are licensed to prescribe drugs, I presume that the rule changes would let them prescribe the pills for chemical abortions that in the vast majority of cases take place not in a medical setting, but in a woman’s home.

We have up to March 5, 2021 to submit comments to oppose these rule changes, which are meant to expand the deadly abortion industry and its profits.

To oppose this, please submit comments by emails and letters, preferably more than once.  Information on ways to submit and two sample comments follow.

CURRENT PROBLEM & WHAT WE CAN DO

 

According to the New Jersey Right to Life, the NJ Board of Medical Examiners has proposed rule changes that would do the following:

  • remove the requirement that abortions only be performed by a physician licensed to practice medicine and surgery and expressly allows non-physician such as Advanced Practice Nurses, Physician Assistants, and Certified Nurse Midwives and Certified Midwives to perform abortions up to 14 weeks gestation in an office setting

  • remove the requirement that abortions after 14 weeks have to be performed in a licensed hospital setting; instead permitting  them to be done in an office based setting

  • remove the requirement that medical professionals performing abortions have admitting privileges at a nearby hospital

 

(More information can be found in the NJ Right to Life’s website, http://njrtl.org/public-comments-due-to-nj-board-of-medical-examiners-by-march-5-2021-on-proposed-abortion-rule-changes/ )

 

The deadline for submitting comments on the rule changes is March 5, 2021.

BY REGULAR MAIL

Comments may be sent by regular postal mail addressed to:

William V. Roeder, Executive Director,

State Board of Medical Examiners,

P.O. Box 183,

Trenton, New Jersey 08625-0183.

Subject Line:  Surgery, Special Procedures, and Anesthesia Services Performed in an Office Setting

To provide comments to the Rule Proposal, include:

Your  Name,  Affiliation and Contact Information (address and phone number).

BY EMAIL 

 

In order to ensure your comments are received, please send your comments concerning any rule proposals via email to:

 

DCAProposal@dca.lps.state.nj.us

Please include the following in your email:

Email Subject Line:  Surgery, Special Procedures, and Anesthesia Services Performed in an Office Setting

Email Body:  Provide Comments to the Rule Proposal
Include: Your  Name,  Affiliation and Contact Information (email address and phone number).

 

SAMPLE COMMENT 1

Subject:  Surgery, Special Procedures, and Anesthesia Services Performed in an Office Setting

The proposed rule changes that were posted on January 4, 2021 must not be enacted because they will license medical professionals who are not physicians to perform abortions, which are the most unsafe of all medical treatments and procedures because they carry a 100% intended mortality rate for babies in the womb.

With every completed abortion there is the death of a baby in the womb – a fact that cannot be overlooked. Another fact is that starting at 20 weeks of gestation babies in the womb can feel pain. Abortions are both painful and deadly to them.

 

It is a great disservice to the public to deny the 100 % mortality rate expected for every abortion while favoring and expanding the abortion industry through the proposed rule changes. Please take all this into consideration and do not enact the proposed rule changes that were posted on January 4, 2021.

SAMPLE COMMENT 2

Subject:  Surgery, Special Procedures, and Anesthesia Services Performed in an Office Setting

The proposed rule changes that would supposedly increase access to abortions in NJ are unjust and unnecessary. They must not be adopted for the reasons given here.

To state that first trimester abortions are minor procedures with few complications is a grave deception, since a death occurs with every abortion. In fact, abortions carry a 100% intended mortality for babies in the womb. This has a particularly detrimental effect on minorities. Counting abortion as a cause of death, in 2009 abortions caused 61.1% of the deaths of non-Hispanic whites and 64.0% of the deaths of Hispanics in the United States. *

There is no need to increase access to abortions in NJ. According to www.findlaw.com,

 

… New Jersey has only minimal regulations for abortion providers and patients… In fact, New Jersey has some of the least-restrictive abortion laws in the country and has abortion providers in most counties.

New Jersey does not require waiting periods, parental consent, forced ultrasounds, or other restrictions on patients.

Abortion providers in New Jersey, however, must comply with some limited restrictions. For instance, the procedure must be performed in a hospital or other specialized facility; services provided after the 14th week must be provided in a “licensed hospital;” and providers offering services after the 18th week must have admitting and surgical privileges within 20 minutes driving time of the facility.

By 20 weeks gestation or earlier a baby in the womb is capable of feeling pain, so it can feel excruciating pain as it is being destroyed during an abortion. This injustice under the guise of “health care” is going on in New Jersey because abortions in the state are legal up to the moment of birth. This must change.

The proposed rule changes posted on January 4, 2021 can be seen by the public as a move by the NJ Board of Medical Examiners to favor abortion businesses and their political supporters while abandoning a duty to ensure that medical care equally values all lives, including those of innocent babies in the womb.

Since the proposed rule changes are unnecessary and unjust, they must not be adopted.

*       Studnicki, J. MacKinnon, S. J., and Fischer, J.W. (2016) Induced Abortion, Mortality, and the Conduct of Science. Open Journal of Preventive Medicine, 6, 170-177.  http://dx.doi.org/10.4236/ojpm.2016.66016