Virginia Regulatory Town Hall
Department of Health Professions
Board of Medicine
Regulations Governing the Practice of Licensed Midwives [18 VAC 85 ‑ 130]
Action Disclosure requirements for high-risk pregnancies
Comment Period Ended on 11/25/2009
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11/25/09  11:19 pm
Commenter: Carol Sakala, Director of Programs, Childbirth Connection

Regulations Governing the Practice of Licensed Midwives

I am contacting the Commonwealth of Virginia as the lead author of the 2008 Milbank Report, Evidence-Based Maternity Care: What It Is and What It Can Achieve. This report was issued jointly by Childbirth Connection (a national not-for-profit organization that has worked for 91 years to improve the quality of maternity care), the Reforming States Group of state-level health policy makers, and the Milbank Memorial Fund (a 104-year-old national foundation that provides decision makers with best available evidence to inform health policy). In a separate communication I have submitted a PDF file of this report to Ms. Elaine Yeatts, Agency Regulatory Coordinator. We are sending paper copies of this report for members of the Board of Medicine to its Executive Director, Dr. William Harp. It can also be accessed online at

We believe that our report might be of use in developing regulations governing the practice of midwifery. In the report, we identify considerable opportunities for improving the quality of maternity care in the United States, and present a framework for understanding evidence-based maternity care. Such care must recognize the physiologic basis for childbearing and ensure that the vulnerable population of childbearing women and newborns receives effective care with least harm. The first broad body of systematic reviews was developed to understand the safety and effectiveness of pregnancy and childbirth care, and many scholars have continued to expand and update this work. Exceptional, abundant and often underused evidence-based resources are thus available to guide maternity practice.

We devote much attention in Evidence-Based Maternity Care to highlighting lessons from recent well-conducted systematic reviews that apply to the care of the majority of childbearing women who are healthy, at low risk, and have good reason to anticipate uncomplicated childbirth. As such, this report is highly relevant to the work of primary maternity caregivers such as Certified Professional Midwives.

We would like to express our concern about the primary focus of the regulations on risk. We strongly encourage the board to address effectiveness as well, and to consider adopting the standard of effective care with least harm, as outlined in the Milbank Report.

We commend the Board of Medicine for its support of midwifery and maternity choices for Virginia's childbearing families. Our report identifies several systematic reviews that are consistent in their support of midwifery care.

Please feel free to contact me if I can provide additional support: or 212 777-5000 x5.

Best wishes,
Carol Sakala, PhD, MSPH
Director of Programs
Childbirth Connection
281 Park Avenue South, Fifth Floor
New York, New York 10010




CommentID: 10181