Jordan Kravitz’s article “Architects call on the Facility Guidelines Institute and AIA to recognize standardized healthcare design recommendations for abortion procedures” contains a number of inaccuracies about the Facility Guidelines Institute’s (FGI) code revision process and the application of the Guidelines for Design and Construction documents. As the CEO of FGI and former managing editor of the Guidelines, I hope to clarify the author’s misunderstandings.
First, a little background is required for context. For your readers who are not engaged in healthcare design, FGI’s documents provide minimum standards for the planning, design, and construction of hospitals, outpatient settings, and residential care and support settings. In states where the codes are adopted, their requirements apply to new health care facilities and major renovation projects for the referenced facility types.
The crux of the author’s complaint is based on a rejected proposal that the author submitted to revise the 2022 edition of FGI’s Outpatient Guidelines. The proposed change added “(e.g., abortion clinics)” to an appendix listing “family planning and reproductive health care centers” as an example of the types of facilities needing to meet the requirements of Chapter 2.2, Specific Requirements for General and Specialty Medical Services.
Now, to the particulars of the complaints. The author asserts that FGI’s Health Guidelines Revision Committee (HGRC), the volunteer, multidisciplinary committee responsible for updating the documents every four years, does not have the reproductive healthcare expertise necessary to make an informed decision on her proposal. The argument that the HGRC lacks the necessary expertise to understand the salient points of the proposal draws a false conclusion. The HGRC is composed of 135 subject matter experts, including doctors, nurses, infection preventionists, facility owners/managers, authorities having jurisdiction, researchers, architects, and engineers. In truth, the HGRC rejected the proposal because it believed “This language is unnecessary,” and the “existing terms cover the types of procedures, and is aligned with most state’s [sic] licensure language.”
As evidence of the HGRC’s supposed lack of expertise, the author calls out Targeted Regulation of Abortion Providers (TRAP) laws that “create burdensome and medically unnecessary regulations on abortion building facility requirements…TRAP laws subject abortion-providing facilities to different requirements than, for example, other surgeries subject only to outpatient-based surgery (OBS) laws.” The author does not seem to understand that FGI’s Guidelines provide minimum requirements for functional aspects of healthcare spaces; they do not direct operational decisions such as where a particular procedure may be performed.
The 2022 Outpatient Guidelines, Section 2.1-3.2.1 (Clinical Service Rooms and Facilities—General) states, “The governing body shall perform an analysis of both the patient population to be seen and the patient care activities to be performed in a facility to determine the clinical service room types to be provided. These decisions shall be documented in the functional program.” This text clearly shows that the owner/operator of the facility is responsible for determining what procedures happen in which room. However, it’s important to note that although FGI’s documents do not determine what room types are required for the clinical services performed, the Outpatient document does list “family planning and reproductive health care centers” as an example of a facility that would follow the requirements of general and specialty medical facilities rather than the more stringent requirements of outpatient surgery centers.
Finally, the author claimed that FGI’s Benefit-Cost Committee (BCC) “agreed” with her proposal, but she misunderstood the BCC’s role in reviewing proposals. When a proposal is submitted to update the code documents, the submitter must indicate if the proposed change will increase or decrease capital costs, patient and staff safety, operational efficiency, and patient care. The BCC, a subcommittee of the HGRC, reviews each proposal and provides a gut-check analysis of the proposer’s stated impacts. In other words, the BCC agreed with the submitter’s cost-benefit analysis, not the proposal itself.
The HGRC is a microcosm of the United States. It’s composed of individuals who advocate including requirements on numerous topics, including on climate change, abortion rights, LGBTQIA+, and other political goals, and as well as those who don’t support such inclusions. Despite these differences, the members of the HGRC consistently choose to put politics aside when revising these important design and construction standards because they believe that’s the best way to protect patients and staff. When proposals contribute to occupant safety, they are added to the code. When they do not, they are rejected. And, when the HGRC doesn’t have enough information to make an informed decision, they bring in subject matter experts to educate themselves.
Working with the HGRC is an honor and a privilege, and it’s the highlight of my career. Members of this committee are unfailingly generous with sharing their knowledge and expertise for the betterment of everyone who accesses healthcare in the United States. They contribute hundreds of professional hours to the massive task of updating FGI’s three Guidelines documents. This group of expert volunteers is dedicated, conscientious, and principled, and they don’t deserve your recriminations. Instead of taking aim at this group of volunteers who perform an invaluable public service, I suggest the author and other interested parties reach out to their elected representatives if they hope to achieve real and lasting change.
Heather B. Livingston is the CEO of the Facility Guidelines Institute.
