By the Policy Center for Maternal Mental Health Policy Team

On April 7th, 2023, the Policy Center for Maternal Mental Health submitted the following letter in support of SB 667, California’s proposed legislation to improve access to healthcare for women and pregnant people across the state by removing barriers and ensuring Certified Nurse-Midwives can practice to the full extent of their scope and training. We believe all states should allow Certified Nurse-Midwives to practice to the full extent of their licenses without restrictions.

RE: SB 667 (Dodd) Healing arts: pregnancy and childbirth – SUPPORT

Dear Senator Roth,

On behalf of The Policy Center for Maternal Mental Health (formerly 2020 Mom), I am writing in support of SB 667 (Dodd). This bill builds upon the recent efforts by the legislature to expand access to health care for women and other pregnant people across the state by removing barriers and ensuring Certified Nurse-Midwives (CNMs) can practice to the full extent of their scope and training. The bill removes and streamlines redundant requirements and creates consistency for CNMs regardless of practice setting. Since the Legislature passed SB 1237 (Dodd) in 2020, CNMs can practice fully independently for “normal,” low-risk pregnancies. They can also collaborate with physicians to care for patients with more complex medical needs. SB 667 addresses the redundancies, and red tape revealed only through the everyday practice of midwives who continue to experience disruptive and unnecessary limitations to practice. SB 667 will rectify these issues so that these highly qualified providers may practice to the full extent of their scope as the original law intended.

Nationwide, poor maternity care access is linked to income, race, and geography (such as rural maternity care deserts). This complex problem requires multiple innovative strategies to turn the tide. Improving access to nurse-midwifery care has been named by leading organizations, such as the March of Dimes and the World Health Organization, as a key innovation for addressing these racial and social disparities.

California has made great strides to reduce maternal mortality and increase access to maternity and reproductive care in recent years. However, racial, economic, and geographic disparities in outcomes persist. For example, Black and Indigenous people remain 3 to 4 times more likely to die from pregnancy-related causes than their white counterparts. Additionally, California is in the midst of a maternity workforce crisis that has left at least nine counties with no OB/GYNs at all and thus has left patients searching for care. The research in recent years is clear: arbitrary limitations on practice only serve to disrupt patient access and continuity of care by CNMs who are otherwise qualified to provide comprehensive care for their patients. This is a costly burden on the health care system and time-consuming – if not impossible – for the patient to navigate.

SB 667 will:

Advance integration and sustainability of independent midwifery care by clarifying that certified nurse-midwives do not have to be “in the same practice with” a physician in order to consult and collaborate.
Strengthen the role of CNMs as providers for disadvantaged populations by clarifying the ability of certified nurse-midwives to dispense medication directly to patients (especially important for FQHCs, community clinics, and free clinics).
Reduce costly barriers to birth center sustainability and start-ups by allowing certified nurse-midwives to perform specific, simple laboratory tests (such as pregnancy tests and urinalysis) within their birth center or independent midwifery practice, consistent with federal CLIA laboratory rules and the scope of their education and training.
Reduce unnecessary appointments (and thus the cost of care), and improve person-centered care, by allowing temporary disability certification by midwives for the entirety of pregnancy, consistent with the certified nurse-midwifery scope of practice (this removes the redundancy of extra appointments and reduces the delay for the patient).
Remove costly, unnecessary barriers to midwifery practice by allowing controlled substances for the treatment of conditions within the CNM low-risk scope to be furnished without the administrative barrier of a standardized procedure, just as all other medications within the CNM low-risk scope do not require a standardized procedure.
Reduce geographic and economic barriers to reproductive health care and improve the efficacy of the nurse-midwifery workforce by extending nurse-midwives' ability to manage common gynecologic conditions across the lifespan (currently, nurse-midwives can manage common gynecologic conditions, but only within certain discrete periods of time centered around pregnancy and conception).
Improve midwifery integration and collaboration within and between different sites of care by allowing hospitals to grant admission and discharge privileges to nurse-midwives, consistent with CNM's scope of practice and if authorized within the hospital’s bylaws.

In order to advance access to comprehensive reproductive care, the Policy Center for Maternal Mental Health supports SB 667. We strongly urge your “aye” vote in committee.

Sincerely,

Joy Burkhard, MBA
Executive Director
Joy.Burkhard@policycentermmh.org

Sarah Johanek, MPH
Policy Project Manager
Sarah.Johanek@policycentermmh.org