On behalf of the Virginia Affiliate of the American College of Nurse-Midwives, I am writing in support of the review and amendment of regulations regarding the inability for Licensed Midwives, to practice to the full extent of their scope and national standards outlined by their certifying body, the National Association of Registered Midwives (NARM). The current regulations in Virginia on Certified Professional Midwives, (CPMs), titled ‘Licensed Midwives”, are in opposition to evidence based recommendations from the World Health Organization and March of Dimes with regard to ability of CPMs to best utilize pharmaceutical agents that are within their education and scope that will have the biggest impact on reducing maternal, newborn and child morbidity and mortality in the community birth setting.

       The midwifery model of care is known to be a key component to improving the health of Virginians during the childbearing years. The purpose of lincensure and regulations are for public and professional safety. Excluding valuable maternal health care providers from prescribing, possessing or administering medications considered life saving, and which would allow them to practice in accordance with national standards, is a barrier to integrating the midwifery model of care into the health system.

       For these reasons we recommend amending the law to remove the exception for prescribing, possessing, and administering medication in 54.1-2957.9 and thus amend the regs 18VAC85-130-80. 

Sincerely, 

Karen Kelly, CM, MS, FACNM 

President-Virginia Affiliate of the American College of Nurse-Midwives