On behalf of the Virginia Chapter of the American College of Nurse
Midwives, I am writing in support of the proposed emergency regulations
governing the practice of certified nurse midwives.  Our members
appreciate the work that has been invested in writing the regulations,
and we look forward to having both the statutory and regulatory support
for changing policies and procedures that have been created in the past
around a supervisory relationship with physicians.

In requesting the change in the Code of Virginia, our members
deliberately removed the phrase, "e.g., periodic chart review" from §
54.1-2957 B because many CNMs and their (supervising) physicians
experienced situations in which physicians expressed concern about their
own liability in reviewing charts on patients that they personally had
not seen.  Keeping a broader statement that is now stated in the Code as
"periodic joint evaluation of the services delivered" better describes
the manner in which collaborating physicians and CNMs can determine
effectiveness of care delivered.  We recommend the removal of the phrase
"e.g., periodic chart review."

Thank you so much.  Please do not hesitate to contact me at  if you have questions.
Anna Lee 1610 Little Page, Fredericksburg VA 22401       804 723 3803

I am writing on behalf of the Virginia Council of Nurse Practitioners (VCNP) in support of the proposed emergency regulations governing the practice of certified nurse midwives (CNMs).

We are pleased the proposed regulations will clarify the relationship between a licensed physician and a certified nurse midwife as one of collaboration and consultation.  CNMs are skilled nurse practitioners who have undergone extensive educational preparation and training in order to meet the rigorous demands of the practice of midwifery .  The proposed regulations serve as recognition of their knowledge and expertise and will enable CNMs to provide greater care to more people throughout the Commonwealth. 

VCNP appreciates the opportunity to submit public comment.  If you have any questions, please do not hesitate to contact me. 

Sincerely,

Carola Bruflat, MSN WHNP

President

Virginia Council of Nurse Practitioners

P.O. Box 11086

Richmond, VA 23230

I am writing in support of the proposed emergency regulations governing the practice of certified nurse-midwives.  I believe that these regulations will be close to the way that we actually practice.  I appreciate all the hard work that has gone into the revisions.

One phrase concerns me, and that is "e.g. periodic chart review" in the definition of callaboration. This phrase was not in SB 488. Physicians do not like reviewing the charts of patients they have not seen.  Chart review is generally done for consultation purposes on higher risk clients.  It is also one element of joint evaluation of our services, which is already covered in a broader sense in the regulations.  Mentioning it specifically leads to burdensome policies for the physicians who work with CNM's.

Thank you for your attention to this detail. We look forward to working with you in the provsion of safe health care for all women and babies in the Commonwealth.

Jessica Jordan, CNM, MSN

2910 Libby Terrace

Richmond, VA 23223

jordancnm@rbvainc.com

804-677-5442