Thank you for providing this opportunity for public comment on the Regulations for Virginia Newborn Screening Services. We are writing in opposition to the proposed method for handling unsatisfactory or abnormal results on the initial screening, as listed on page 18 (12VAC5-71-80-D3). “If a licensed midwife has ordered the newborn-dried-blood-spot screening test and is notified that the results are unsatisfactory or abnormal, the infant shall be immediately referred to a physician or health care facility for repeat collection and submission and for care and treatment as necessary.” It appears here that Licensed Midwives are required to refer to a second health care provider or facility to repeat an unsatisfactory blood-spot screening if the child has been born outside the hospital. An unsatisfactory screening can occur under normal circumstances including mishandling of the specimen at any point along the way—something that can be as difficult to control as the weather (should the specimen be exposed to extreme temperatures en route, for instance). To date the lab’s response has been to return, to the midwife, another card for repeat collection. The midwife obtains a second sample and returns it to the laboratory for submission. This process has been working satisfactorily. The proposed regulation seems to require that the midwife should somehow deliver the second card to a different practitioner or facility, [with whom the parents would then need to arrange the re-test, all within two business days.]. Such a requirement would make the procedure more complicated than necessary, and could significantly compromise timely compliance. Having the midwife re-test is the simplest solution and will likely result in the desired result (a proper screen). Is there evidence to suggest that the current, less complicated system is not working satisfactorily? Handling abnormal screening results is addressed elsewhere in the regulations and thus, needs no further direction here. Again, we request that this section be removed as unwieldy, unnecessary, and fraught with potential for miscommunication and error. Rebecca Bowers-Lanier Commonwealth Midwives Alliance