Hello.  I am a mother of three and a journalist.  Evidence is important to me when I make decisions affecting my family, as well as in my professional life.  I am encouraged that this regulatory action is intended to make sure that consumers have access to any available evidence related to health risks associated with  out-of-hospital births.

I look forward to a future regulatory action that will do the same for consumers in terms of health risks of in-hospital obstetrical procedures, as well.

I read with interest the text of the proposed change, and have some concerns about the wording of Item #3 under "Substance".    Here is the text:

"If the factors or criteria have been identified that may indicate health risks associated with birth of a child outside a hospital, a requirement for the midwife to provide evidence based information on such risks. Such information would be specified by the Board for certain conditions and would include statements and evidence from both the medical and midwifery models of care."  

"Evidence",  if genuine,  is an improvement as a basis for decision-making,  over tentative conclusions  reached through  the interpretation of competing opinions.   The current wording makes it appear that opinions or perspectives  from competing  "models of care", rather than objective research results, will be the basis for information the midwife will be required to share.

If by "statements" the drafters of this text intend to mean "opinions", then I would have to argue that there should be no place for them in the Informed Disclosure documents that midwives will give to home birth clients..  

I would encourage drafters to be exceedingly careful to base the substance of the required information on objective evidence, rather than subjective opinion.

Thank you for your diligence and service in this effort,.

Respectfully,

Jennifer Downey

101 Bollingbrook Dr.

Charlottesville, VA  22911

434-971-4679

jsdowney@earthlink.net