My name is Karen Kelly, I am a Certified Midwife, a fellow of the American College of Nurse-Midwives and the president of the Virginia Affiliate of the American College of Nurse-Midwives.  Enacting these regulations moves forward Virginia’s ability to scale up and meet the demand for maternity and primary care services at a time when more than half of the counties in Virginia have no hospital based obstetrical care. The need to travel long distances to access care is a critical factor why women do not seek care. In more urban areas of the Commonwealth we are still not close to achieving recommended ratios of reproductive health care clinicians.  

        Multiple studies show that midwifery care has long been associated with lower rates of interventions, particularly cesarean sections and inductions, while maintaining excellent safety outcomes. Investing in midwives, and in this case specifically Certified Midwives, can help fill these gaps in the workforce, reduce the rate of medical interventions and bring down costs. 

       These regulations were successfully drafted with the input of the Board of Nursing and a team of Certified Nurse-Midwives and Certified Midwives and represent a near-full-scope utilization of Certified Midwives, in accordance with standards-setting documents from the American College of Nurse-Midwives and the American College of Obstetrics and Gynecology. 

       We are grateful for the efforts of the Department of Health Professions and other stakeholders to support policy that promotes a more patient-centered healthcare system. The proposed regulations meet recognized standards for Advanced Practice Midwifery and promote the delivery of high quality-care to the public. 

       As we continue to develop quality improvement efforts aimed at reducing maternal and perinatal mortality and morbidity, we look forward to seeing Advanced Practice Midwifery integrated alongside initiatives for Advanced Practice Nursing.  To fully realize the potential of Licensed Certified Midwives, we urge you to identify mechanisms for further investment in midwifery, such as education and training programs targeted to residents of the state. 

       On a personal note, I am one of a handful of Certified Midwives living and working in the state. As Certified Midwives, we were educated side by side with our nurse-midwife colleagues. We completed the same clinical rotations, and sat for the same exact board certification exam through the American Midwifery Certification Board as the certified nurse-midwives already practicing in Virginia. 

       Collectively we have worked in hospitals, led midwifery units, earned doctorates, held positions of leadership within ACNM, worked as educators and preceptors and taught student nurse-midwives and midwives, Physician Assistants, medical students and residents. 

       I have the privilege of currently serving on the governor-appointed task force on Maternal Data and Quality Improvement Measures, and the Department of Health Professions work group on midwifery in 2021. What I have not yet been able to do since moving to Virginia with my family in 2016, is clinically practice as a midwife. 

       I am aware of a handful of student midwives in Virginia who began their Master’s degree in midwifery as soon as the bill was signed into law in 2021. They are about to graduate at the end of this year. I have heard from others in Virginia who will be starting their Master’s degree this September. On behalf of these midwives and all who seek access to midwifery care, I urge you to move forward the proposed regulations without unnecessary delay, so that these midwives can help meet the needs of our state to improve maternal and newborn health outcomes. 

       Thank you for your time and consideration on this issue.