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