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