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
Previous Comment     Back to List of Comments
11/26/09  12:10 am
Commenter: Lisa Pratt, JD Candidate, University of D.C., David A. Clarke School of Law

Reconsider this regulation

Please, reconsider passing this regulation that is harmful to the women you are trying to protect.  Women seeking vaginal birth after cesarean (VBAC), vaginal breech and vaginal twin births are increasingly finding their options limited to a surgical delivery regardless of her individual needs.  Thousands of hospitals across the nation have banned these types of birth vaginally, requiring women to undergo a surgical delivery regardless of individual risk and out of fear of legal liability, not medical necessity, effectively denying women any informed consent of meaningful choice.  The risks associated with these types of deliveries are minimal and risks associated with having a cesarean cannot be ignored when considering the balance of harms.  When women are forced to choose between unassisted births and hospital births that they don't desire, it is reasonable to expect an increase in black market births, emergency transports where no prenatal care was established beforehand, and unassisted births for which families may not be fully prepared.  This ultimately creates additional burdens for the system. It makes greater sense, both from a consumer rights standpoint, and an economic one, not to require additional risk assessments beyond what is already required by the current law.

CommentID: 10184