Abortion Clinic Workers:

What To Report

Whether you know it or not, you may be an unwitting accomplice to a crime. If you are aware that any of the following activities are occurring in the facility where you work, you should take immediate steps to protect yourself.

Financial Rewards

A significant number of the practices outlined below are illegal, and in many cases there are significant financial rewards paid for information about these crimes. This is especially true for crimes involving income tax evasion, Medicaid fraud, or insurance fraud.

However, as we’ve indicated elsewhere, timing is extremely crucial. Any information you have is probably known by others as well. We pointed out earlier that if several people in an office have knowledge of illegal activity, the first person to come forward with it is the one who gets protection. Generally speaking, that also applies to rewards. They are usually paid to the first people who provide information, not everyone who provides information.

In those cases where there is no financial reward, that doesn’t mean there aren’t incentives for coming forward. To begin with, never underestimate the satisfaction that comes from simply knowing that you did what is right. Additionally, as any one who has ever been in this situation will tell you, there is a tremendous sense of relief when you find out that information you provided to the authorities is going to keep you from going to jail.

An increasing number of abortionists are now killing late term babies after they have been born in order to avoid incurring a botched abortion and/ or a civil suit. Killing a baby after it has been born is considered murder under the law; and anyone who assists with this can be charged.

Yes answers to any of the following questions could be red flags to look out for.
  • Does your clinic offer late-term abortions?
  • Are patients giving birth before their appointments?
  • Has the doctor ever inserted too many laminaria to where the patient went into labor before the procedure?
  • Have you ever seen the doctor snip/twist the neck of a baby or jam instruments into the baby’s body?
  • Have you ever seem any movement from a “dead” baby?
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Every state in America has an age below which minors cannot consent to sexual activity.

This ranges from 14-years-old to 18-years-old, depending on the state. Any adult who engages in sexual activity with a girl under this age is committing statutory rape and is open to criminal prosecution. More than 12 years of research has revealed that the vast majority of clinic workers and family planning service employees fail to report cases of statutory rape. In undercover conversations, many clinic personnel even went so far as to coach a 13-year-old girl on ways to cover-up this crime.

Additionally, every state has mandatory reporting laws that require health care workers, counselors and other designated reporters, to inform the state’s designated agency if they have reason to suspect that a minor is engaging in sexual activity.

The law does not permit healthcare workers to decide which cases should be reported. It is not the job of a mandated reporter to investigate cases of child abuse. You are required to report all such cases. It then becomes the job of child protective services or the designated state agency to investigate these cases.

Every underage girl who seeks an abortion, birth control, or treatment for STDs are all indications of sexual activity and is a potential victim of statutory rape and must be reported. Any clinic worker or ‘family planning service’ employee that does not alert authorities when statutory rape is known or suspected may be exposed to criminal prosecution for failing to report this possible abuse.

Beware of policies and procedures that are designed to solicit business from underage girls by promising them confidentiality along with abortion services or birth control. Confidentiality in these cases is actually illegal because it would violate mandatory reporting laws. If a clinic owner or manager instructs you not to report these cases or encourages you to circumvent these laws by ‘looking the other way’, then they are conspiring to violate the law. Covering up statutory rape or other abuse is a crime, even if you are acting under instructions from your employer to do so.

Failure to report your suspicions that a minor may be sexually active can result in charges being brought against you, like obstruction of justice.

In addition, you could be held liable for civil damages should the victim of this abuse or a parent of the victim file a lawsuit that involves your failure to comply with mandatory reporting laws. Furthermore, you could also be named in lawsuits filed by any subsequent victim of statutory rape or other abuse, if it turns out that the perpetrator of this abuse escaped detection by law enforcement at an earlier date because of a case that you failed to report.

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If you feel that you or your co-workers have been subjected to inappropriate sexual comments, language, discussions or behavior by your employer, or if you feel that your employer tolerates this sort of thing on the part of other employees, call Life Dynamics for advice about your legal rights and options.

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At Life Dynamics, we have identified many instances of patients being sexually assaulted by abortion providers.

Additionally, since women often don’t want anyone to know that they had an abortion, they tend to be reluctant to report sexual misconduct inflicted upon them while at an abortion clinic. This means that this behavior can go undetected for a long time.

Having recognized that clinic employees may not know the signs that someone they work for is sexually assaulting patients, we have prepared the following list of questions as a guideline. (Yes answers indicate that such activity could be occurring.)

As you analyze these questions, there are several things you should consider…

First, if you or other employees are being sexually harassed by your employer, or if your employer tolerates other employees doing so, there is a heightened risk that this person may be sexually harassing or even sexually assaulting patients.

Second, remember that while most inappropriate or illegal sexual activity involves male predators and female victims, it is not limited to that scenario. On several occasions, we have been advised by employees of abortion clinics operated by female doctors and/or directors that these women are sometimes guilty of sexually victimizing patients.

Third, always listen to your instincts and keep your mind open for other possible red flags not addressed by the questions below.

  • Do your intake forms indicate whether other people know that the patient is there? For example, are minor patients asked if their parents know that they are having an abortion? Are married patients asked whether their husbands know that they are having an abortion?
  • Does the doctor ever insist on being left alone while performing procedures?
  • Are operating room doors ever locked during procedures?
  • Have you ever noticed patients having a dramatically different attitude after their abortion than before? Do some patients show unexplained anger or fear after procedures, or seem in an inordinate hurry to get out of the clinic?
  • On follow-up visits, do patients ever ask to see a different doctor than the one who did their procedures?
  • Have you ever noticed doctors or other employees taking addresses or phone numbers off patient charts?
  • Are patients who are accompanied by parents, boyfriends, or husbands treated differently than those who are alone or accompanied by friends?
  • Are physically attractive patients treated differently than those who are less attractive?
  • Have you ever heard a doctor or other employee make comments about a patient’s physical appearance, body shape or sexual attractiveness?
  • Have you ever heard a doctor or other employee ask inappropriate or unnecessary questions about a client’s sex life?
  • Have you ever heard a doctor or other employee offer comments or speculation about what kind of sexual activity a patient may be willing to engage in?
  • Have you ever heard someone make jokes or express suspicions about a doctor or other employee in your facility having sexual contact with staff or patients?
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As an employee of an abortion clinic, you have a moral and legal obligation to report any physical attacks committed upon a patient. Always be aware that people who physically attack others often do so in a way that is not obvious or easily detected.

Have you ever seen or heard about a the following happening at the clinic:

  • Striking a patient
  • Restraining a patient or locking a patient in the procedure room
  • Not allowing a patient to leave the facility
  • Not allowing a patient to change her mind about having the procedure
  • Verbally intimidating patients
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Money laundering is the process of concealing the source of large amounts of money that have been gained through illegitimate means.

When someone wants to find a way to launder money, one of the best ways to do that is by setting up a business that handles large sums of cash. Since almost no abortion clinics accept personal checks, and since many patients don’t have credit cards or don’t want an abortion showing up on their monthly bill, this means that there is lots of cash flowing through the facility. Most employees will have no way of knowing for certain that the clinic at which they work is being used to launder money.

However, if you answer yes to one of the following questions, that could be an indicator that money laundering is occurring.

  • Are employees ever paid in cash rather than by check?
  • Are employees paid by check, but prohibited from leaving the clinic with the check and instead required to sign it back over to the clinic in exchange for the cash amount?
  • Is there a person routinely present at the clinic who does not appear to have a role in clinic operations but demonstrates an interest in the clinic’s financial transactions?
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Do not be deceived into thinking that insurance and Medicaid fraud are minor issues.

Not only does law enforcement pursue these crimes vigorously, but costs our nation billions of dollars. Every year the insurance industry spends millions of dollars to help authorities catch those involved in insurance fraud. If your clinic is involved in Medicaid fraud, your future is in jeopardy. The United States Department of Justice has made prosecuting this crime one of its top priorities. Make no mistake, people go to jail for insurance fraud.

The following questions should help you determine whether this crime is being committed in the clinic where you work.
Yes answers should be seen as red flags. (Note that insurance fraud is often accomplished by using some of the same techniques as Medicaid fraud.)

  • Are non-Medicaid patients ever allowed to use another person’s Medicaid card?
  • Are procedures performed on one patient ever billed to another person’s insurance company?
  • If insurance of Medicaid is paying for an abortion, are gestational ages ever exaggerated in order to justify higher billing rates?
  • Are insurance companies ever billed for services that were never provided (STD testing, STD treatment, ultrasound, etc.)?
  • Does the clinic ever charge a patient for an abortion, and then also bill her insurance company or Medicaid for the same procedure?
  • If a patient’s insurance policy doesn’t cover abortion, does the clinic take her insurance information anyway and then bill her insurance company for the component parts of the abortion? For example, do they trick the insurance company into paying for an office visit, internal exam, sonogram, counseling, vaginal swab, cervical dilation etc.? (This “unbundling” scheme almost always results in a bill to the insurance company that far exceeds the amount that cash-paying patients are charged.)
  • If a patient’s insurance policy or Medicaid doesn’t cover abortion, does the doctor ever cause what appears to be a spontaneous miscarriage and then bill for performing a D&C? For example, are Medicaid patients ever given a drug or a laminaria insertion with the intent of producing what appears to be a spontaneous miscarriage so that a D&C can be performed and billed to Medicaid?
  • In circumstances where Medicaid does not pay for abortions, are Medicaid patients ever offered a discount for providing their Medicaid cards to the clinic? This may indicate that the clinic is going to “unbundle” the procedure and charge Medicaid for the component parts. In other words, instead of charging Medicaid for an abortion, they will charge for ultrasound, vaginal swab, cervical dilation, etc. It could also indicate that they are going to bill Medicaid for services that were not provided (STD testing, STD treatment, ultrasound, etc.).

If your clinic is involved in Medicaid fraud, your future is in jeopardy. The United States Department of Justice has made prosecuting this crime one of its top priorities.

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Because abortion clinics primarily operate on a cash basis, they create an environment in which it is very easy to avoid paying taxes owed to the Internal Revenue Service. Do not think that the IRS takes this matter lightly- this is an extremely serious issue. Rest assured that America’s federal penitentiaries are full of people who made that mistake.

A YES answer to any of the following questions may indicate that your employer is involved in income tax evasion.

  • Has your employer or director ever taken cash out of the clinic’s bank deposit?
  • Has your employer or director ever taken cash from a patient and not put it in the clinic’s bank account?
  • Does your employer ever cash large personal checks at the clinic?
  • Does the clinic have more than one book from which patients are given receipts for cash payments?
  • Does the clinic ever fail to give receipts for cash payments?
  • Have you ever seen evidence that cash amounts taken in by the clinic don’t match the clinic’s bank deposit?
  • Does your employer or director use multiple accounting ledgers?
  • Are financial records ever written in pencil?
  • Is the person who makes bank deposits different from the person who counts the money taken in?
  • Are patient medical records ever destroyed or discarded?
  • Are clinic financial records ever altered, destroyed, or discarded?
  • Are employees ever given cash by clinic management?

If you are aware that this is occurring in the facility where you work, you should take immediate steps to protect yourself.

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If you answer yes to any of the following questions, it may indicate that your clinic is deceiving or defrauding its patients in order to secure additional business or increase profits.

Again, remember that these women place their trust in you at a very vulnerable time in their lives. The clinic has a legal and moral obligation to treat them fairly and honestly.

  • When a potential patient calls, are employees trained to say whatever they need to say in order to get the patient into the clinic for an appointment?
  • Are underage girls promised confidential services, in spite of mandatory reporting laws which would make such an arrangement illegal?
  • Does your facility use advertising to solicit business from minor children in another state and/or are minors encouraged to use your facility in order to circumvent their own state’s parental consent law?
  • Do policies or practices at your clinic permit employees to offer birth control or abortion services to underage girls without informing these minors that mandatory reporting laws require clinic employees to report every such case to the state (in order to protect against statutory rape or other abuse) ?
  • Are counselors trained in how to overcome a patient’s objections to having an abortion?
  • Are clinic employees given commissions or bonuses for selling abortions, or for “up-selling” the patient and convincing her to pay extra for general anesthesia over “twilight sleep?”
  • Are patients ever told they are further along than they actually are so that the clinic can charge them more for the procedure?
  • Are counselors ever told to deceive patients about the clinic’s or the doctor’s history of malpractice or safety record?
  • Are counselors trained to downplay patient questions related to the fetal development such as making claims about it being “just a blob of tissue” or “a mass of cells?”
  • Are patients ever given relaxant drugs prior to counseling?
  • Does the price of the same procedure change from one patient to another?
  • Have you ever been instructed to administer sedation to a patient who is asking too many questions about the procedure?
  • If a patient has already had laminaria installed and wants to change her mind, is she ever told that it cannot be done, or that the fetus is already dead, or that removing the laminaria would be dangerous for her?
  • Are patients who want to change their minds ever told that they can’t get their money back?
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A YES answer to any of the following questions may suggest that your employer is cutting corners on health and safety standards, and is thereby placing you or the patients at risk.

As you consider these questions, remember that if your employer is engaged in illegal or unethical behavior, the women who come to your clinic can be emotionally and physically scarred for the rest of their lives. Because these women trusted you with their health and safety at a very vulnerable time in their lives, you have an ethical and moral obligation to take these issues seriously.

  • Are bio hazardous waste products (bloody materials, uterine contents, aborted fetuses, etc.) ever discarded in containers not specifically intended for biological waste, or otherwise discarded in a non-approved manner (thrown into a dumpster, put in a garbage disposal, flushed down the sewer system, etc.) ?
  • Are body fluids and blood products handled in a way that would increase the possibility of an employee contracting Hepatitis or HIV?
  • Has the clinic management ever refused to provide employees with Hepatitis B vaccinations?
  • Are surgical instruments ever cleaned without being sterilized?
  • Are disposable cannulas, speculums, tubing, or gloves ever reused?
  • Is laminaria ever reused?
  • Are procedures past 13 weeks ever done using manual dilators alone?
  • Is there a deficiency in emergency equipment or procedures?
  • Is there an unusual protocol for requesting an ambulance?
  • Are patient medical records ever altered, destroyed, or discarded?
  • Does clinic procedure include listing a nurse who was not at the clinic at the time of the procedure?
  • Does the doctor ever leave the building before all patients are dismissed?
  • Are abortions ever performed without first using a sonogram to accurately determine gestational age?
  • Are patients’ vital signs ever skipped or simply made up?
  • Is general anesthesia ever administered by staff members who are not either an anesthesiologist or a nurse anesthetist?
  • Are controlled substances ever secured improperly? Also, are blank prescription pads ever signed by a physician (or another legally authorized person) and then left in an environment where they can be filled-out and dispensed by employees who are not legally authorized to write prescriptions? (Never overlook drug use by clinic staff. There are plenty of opportunities in any medical clinic for employees to have access to drugs, and any abuse of drugs puts both patients and staff at risk. Protect yourself and report any misuse of drugs taking place in your clinic or by clinic personnel.)
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In any work environment, employees may see their employers do things that appear to be uncalled for, unjustified, or unexplainable. In most cases, these events don’t necessarily mean that anything unethical or illegal is taking place. However, YES answers to any of the following questions could be red flags to look out for.

  • Does your facility fail to inform employees and volunteers that mandatory reporting laws require them to treat every underage girl seeking an abortion or birth control as a potential victim of statutory rape or other child abuse and that all such cases must be reported to the state?
  • Are employees or volunteers allowed to coach underage girls on how they can circumvent laws that require parental involvement? In cases of statutory rape, do employees at your facility ever coach underage girls on how they can help their adult sexual partners avoid detection by law enforcement?
  • Have the owners or managers of the clinic established policies or practices that encourage staffers not to comply with mandatory reporting laws? Do they ever suggest that clinic business could suffer if the staff complied with these laws or do they try to convince clinic workers that these laws do not apply to underage girls who seek birth control or abortion services?
  • Are unexplained firings common in the clinic? If so, it could be that the fired employees found out something about your employer, or began to ask uncomfortable questions. In short, unexplained dismissals could indicate that your employer was getting nervous that the employees involved were catching on to some illegal or unethical activity being committed at the clinic.
  • Is there an unusually high turnover rate of employees? If an employer is trying to hide illegal or unethical activity, the last thing he wants is people surrounding him who know too much about his operations. In this situation, it is common for employers to keep employees in the dark by continually replacing them. That way, employees never become involved enough in clinic operations to discover any of the inappropriate behavior.
  • Has the clinic hired anyone with a known drug problem or failed to fire a staff member who has a drug problem?
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At Life Dynamics, we have extensive experience helping abortion clinic workers who are in this situation.

If you have been a witness to, a participant in, or a victim of illegal activity taking place in an abortion clinic, you should immediately call to get the advice and assistance you need. There are no charges for our services.

Call (940) 380-8800 Monday through Friday, 8:00 am to 5:00 pm (Central).

If you want to provide documents anonymously, you can send them to:

Life Dynamics Incorporated
Post Office Box 2226
Denton, TX 76202