To whom it may concern:

  I am writing in response to the proposed regulatory change to the Regulations Governing the Practice of Licensed Midwives in Virginia.  First, I believe that this proposed change is clearly redundant to the obligations to which all of Virginia's Licensed Midwives are already bound under the pre-existing Midwifery Model of Care.  As such, this is a waste of extremely limited state funds for the purpose of improving healthcare in the Commonwealth.  Additionally, the redundance such an adopted change would create could also have unintended negative consequences in chilling the environment in which health care consumers are able to not only consider, but act upon, all of the evidence-based research available to them regarding every aspect of maternity care, most especially those areas which may be defined as high-risk by certain obstetric care-providers.

  Virginia's Licensed Midwives are already providing REAL, EFFECTIVE informed consent to their clients regarding the risks associated with home birth, home birth after cesarean surgery, home birth of twins, home birth of breech babies, home birth for diabetic mothers, and home birth for women of so-called advanced maternal age.  This informed consent ALREADY includes the provision, by Virginia's Licensed Midwives, of current, evidence-based research on the relative risks and benefits of homebirth in each of these scenarios, as well as the always-present option of consultation or referral to obstetric care if the client so chooses.  I CANNOT say the same is currently being providing to Virginia's birthing families who elect obstetric care in a hospital setting.  As an erstwhile attendant of hospital births in Northern Virginia, I can attest that I have often seen an utter and complete lack of informed consent given to birthing women on any and all manner of non-emergent issues which arise in the course of labor and childbirth by their obstetricians and the other hospital personnel attending them.  When will the Board of Medicine take action to require fulsome, timely informed consent by obstetricians and other hospital-based maternity care providers?

  Certainly, all maternity  care consumers in the Commonwealth are entitled to full disclosure of the known risks and benefits attached to their health care choices.  Happily, the client's of Virginia's Licensed Midwives ARE ALREADY RECEIVING THIS.  Consumers are choosing homebirth after deliberate and careful consideration of the risks and benefits, including in those situations where obstetricians may not feel comfortable delivering other than surgically.  THIS IS THEIR LEGAL RIGHT.  Do not impinge on consumer's rights or waste the taxpayer's money by adopting these unnecessary regulations.