Please reconsider new changes about practice agreements for these following reasons:

**All the national Advanced Practice Nursing Organizations oppose practice agreements and promote independent practice.

**Virginia CNMs have been safely practicing for the last 6 years without supervision by other professions. With the new law and these regulations we are under a team leader physician which is not collaborative practice. This leads to limitations in practice, difficulty in opening midwifery owned and midwifery run practices and restricts hospital admitting privileges.

**Nurse-midwifery practice in Virginia should follow the Standards of the American College of Nurse-Midwives which allows for independent practice.

**These rules increase the regulatory burdens on certified nurse midwives, increase cost of care, and decrease access to care while providing no benefit to the public.

               Thank you,

               Jennifer Cheney, CNM in Norfolk, VA