The main objective of unregulated pregnancy clinics (UPCs) is to prevent clients, either by persuasion or delay, from having an abortion. In furtherance of this mission, UPCs present themselves falsely as conventional “free clinics” to lure in people who believe they need medical care for a pregnancy.
About 75 percent of UPCs offer “limited ultrasound” examinations, which means they are conducting a medical examination but in an extremely narrow manner. Clients believe they are visiting a clinic which diagnoses and treats medical disorders, but that is not the case at a UPC. Their ultrasounds are little more than showing pictures of the womb in the hope that, once seen, clients will bond with the fetus and not seek an abortion.
These “medicalized” UPCs certainly look like conventional clinics, with a waiting room, an examining room, and medical equipment. There are even mobile UPCs designed to look like conventional medical facilities. As ICU Mobile, “A Ministry Division of Care Net,” concedes: “ICU Mobile units are neutrally-branded and medically designed. By having this independent brand, we break down the barriers that may prevent abortion-minded women from coming on board…” Another set of mobile UPC trucks, from Save the Storks, have painted on the sides: “Women’s Choice Center,” “Pregnancy Testing & Ultrasound,” and “mobile medical unit.”
Clients seeking pregnancy services need honest and nonjudgmental medical services. The American Medical Association “advocates that any entity offering crisis pregnancy services…truthfully describe the services they offer or for which they refer—including prenatal care, family planning, termination, or adoption services—in communications on site and in their advertising, and before any services are provided to an individual patient.” They are right.
Many legislative efforts to address fraudulent advertising by UPCs have failed because of the way they were written. The UPC Playbook legislation is different, however, because it is not limited to UPCs; it applies to false advertising by any health care services entity. That makes the legislation defensible in court, which is why Vermont amended its law in 2025 to this version. While it may seem like a significant change in scope, states already have laws against fraudulent advertising that apply to enterprises that charge for their products or services, including health care providers. So, the real effect of this model is limited, extending false advertising prohibitions to include free health care entities, such as UPCs.
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