Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Medicine
 
chapter
Regulations Governing the Practice of Licensed Midwives [18 VAC 85 ‑ 130]
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8/16/22  10:41 pm
Commenter: Meagan Flaherty

Virginia Midwifery Laws Must Change to Reflect National and Global Midwifery Practice Scope of Care
 

Honorable Members of the Board, 

Certified Professional Midwives (CPM) play an important role within our communities by providing alternative quality perinatal health care options to the families living in Virginia, as well as helping to ease the strain on the already overburdened hospital systems.  Community birth in home and birth center settings along with receiving excellent antepartum, intrapartum, and postpartum care with licensed midwives is becoming more and more mainstream both locally and nationally.  Virginia saw a clinically significant rise in the number of home deliveries between 2019 and 2020 compared to 2018 to 2019, and will likely continue to trend upwards (Gregory, Osterman, & Valenzuela, 2021). This rise can be attributed to a number of factors including families becoming more aware of the maternal health crisis in the United States, the high rate of interventions even with low-risk pregnancies and births that are utilized in hospital settings, fear of being exposed to COVID in hospital settings, being aware that midwifery care has shown to improve outcomes in low-risk pregnancies, and lack of access to perinatal care providers or hospitals within their local communities.  

Current Virginia midwifery laws and regulations restrict Licensed CPMs within our state from prescribing, carrying, or administering controlled substances that are recognized as being within their scope of practice on both nationally and globally (International Confederation of Midwives, 2019; North American Registry of Midwives, 2016).  This is problematic because not only does Virginia law mandate that Erythromycin eye ointment be administered to the newborn as soon as possible after delivery yet CPMs are prohibited by law to do so, CPMs are also unable to manage common conditions such as dehydration during labor with IV fluids or administer Rho(D) immune globulin to Rh- clients.  In addition certain complications that could be appropriately managed in a home or birth center setting with medications, such as postpartum hemorrhage, require hospital transfers which are disruptive to the important physiologic processes after delivery that ensure appropriate bonding between the mother/infant dyad as well as establishing lactation, they are also a burden on the health system.  Lastly, to deny trained perinatal healthcare providers such as CPMs access to live-saving medications for emergency situations is akin to telling birthing families that the Virginia Medical Board views them as just another statistic, and not worthy of access to the full scope and care that the North American Registry of Midwives (NARM) and the International Confederation of Midwives list as part of the essential skills a midwife must possess.  

It is imperative that you review the current midwifery regulations restricting controlled substances and make positive change for the mothers, babies, and families within our state by allowing licensed CPMs unrestricted access to the medications and therapies that NARM lists as part of their accepted scope of practice.  Please show the families of Virginia that you are committed to ensuring that every pregnant person has access to safe, quality, and comprehensive midwifery care.  

Respectfully, 

 

Meagan Flaherty

References 

Gregory, E., C., W., Osterman, M., J., K., & Valenzuela, C., P. (2021). Changes in home births by race and hispanic origin and state of residence of mother: United States, 2018–2019 and 2019–2020. National Vital Statistics Reports, 70(15), 1-10. https://www.cdc.gov/nchs/data/nvsr/nvsr70/NVSR70-15.pdf

International Confederation of Midwives. (October, 2019). Essential competencies for midwifery practice [PDF]. https://www.internationalmidwives.org/assets/files/general-files/2019/10/icm-competencies-en-print-october-2019_final_18-oct-5db05248843e8.pdf

March of Dimes. (June, 2021). Maternity care desert. March of Dimes Peristats.  https://www.marchofdimes.org/peristats/datareg=99&top=23&stop=641&lev=1&slev=4&obj=9&sreg=51

North American Registry of Midwives. (2016). 2016 NARM job analysis survey comprehensive report [PDF]. Inteleos Psychometric Services. http://narm.org/pdffiles/2016-Job-Analysis.pdf

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