These rules increase the regulatory burdens on certified nurse midwives, increase cost of care, and decrease access to care while providing no benefit to the public.

evidence shows midwives are beat for low risk women. Lets keep midwives available for virginians. They save health care costs, and requiring oversight by physicians will increase health care costs at a time the economy can't afford it.

As outlined in my comments on the regulations for nurse practitioners, any requirement to have a physician sign any kind of agreement or requiring any other physician supervision, leader, etc.  for CNMs to be able to able to practice, including the prescribing medications, contraceptive devices, physical therapy, etc. is against the Standards of the ACNM.   The limitations placed on CNMs by this law and regulations are a restraint of trade that increases the costs of health care, take up valuable physician time,  and decreases access to care.  There is no evidence that requirements for physician leadership, supervision, chart reviews or agreements improve the public safety.

We are educated, we are certified, we are licensed, we are credentialed, we are insured,  we have spent years and years and tens of thousands of $$ getting degrees and clinical experiences.  Yet we remain bound by these legal chains. CNMs are responsible for their own care.  We want to practice our trade as free people.  Again I ask the General Assembly, Governor, and Joint Boards for our God-given right to practice our trade without this unconstitutional restraint.

I respectfully disagree with both pieces of legislation as both 18VAC90-30-10 and 18VAC90-40-10 will remove Certified Nurse-Midwifes' ability to practice independently/collaboratively and would instead require them to be part of a "patient care team" with an OB at the head -- a blow to CNM autonomy.

The model of care that a pregnant woman receives from a CNM for a healthy woman with a normal pregnancy is superior to what she could receive from an OB practice, where the likehood of having interventions that could harm the mother and/or baby are hightened.

The current C-section rate in the USA is around 30% much higher that the World Health Organization recommends, (15%). The cost involved in unnecessary interventions increase the cost of delivery.

In all, these legislation will not help womens and babies in VA. It will only increase the risks and costs.

I don't think that putting more restrictions on CNM's will help pubic safety or the economy. If anything it will hurt midwifery care. Midwives are trained professionals and have spent many hours and many dollars to do so. As a mother and an aspiring midwife I am saddened to see that so many laws are making it difficult for one of the best forms of care for low risk women who want a midwife. It saves costs and provides more of a one on one care for these women. If there are more restrictions it will be like taking away ones livelihood. Being one of those women who have benefited in this community from midwifery care and know many midwives who will be affected by this is again saddening. All of the national Advanced Practice Nursing Organizations oppose practice agreements and promote independent practice. I would like to see it kept that way as well. 

Please remove CNMs from this proposal and allow them to continue working independently to offer women the best in midwifery care.