This Action Alert has a June 30th Deadline!
Currently, the Department of State Health Services (DSHS), which houses the Texas Midwifery Board, is being reviewed by the Texas Sunset Advisory Commission. The Commission has recommended that the Texas Midwifery Board be moved to the Texas Department of Licensing and Regulation (TDLR). TDLR regulates many professions including cosmetologists, electricians, and tow truck operators. Since the staff at DSHS has experience in healthcare issues, we believe the Midwifery Board should not be moved. This move would also take away the Board’s rule making authority, an ability crucial to continually improving safety and best practice standards.
The bigger issue is that ACOG and TCOG, the professional organizations of Obstetricians and Gynecologists are using this review as an opportunity to recommend changes to the Texas Midwifery Law. Both the Association of Texas Midwives (ATM) and Texans for Midwifery (TfM) are strongly against this.
Below are talking points and instructions on how to submit comments to the Sunset Review Commission.
• Please try to use your own words when submitting comments with the talking points as a guide.
• It is helpful to state your personal experience with midwives but do not give details. For example, DO say, “I have experienced the excellent care of a Licensed Midwife through 2 pregnancies and births” but do not share the details of your birth story.
• Be positive! Don’t be negative about doctors and hospital, but instead be positive about midwives.
• Keep it Short! It should not be longer than 1 page.
Instructions for submitting comments to the Sunset Review Commission:
1. Go to the Sunset Advisory Commission website https://www.sunset.texas.gov//contact-us
2. Click on Public Input Form
3. Select Department of State Health Services (DSHS) from the drop-down menu
4. Use the talking points and your personal experience to write comments.
For the section titled “Your Comments About the Staff Report:
• The Texas Midwifery Board is not due for Sunset Review until 2016-2017. Any changes to the make-up of the Midwifery Board or it’s law or rules should be tabled until that review.
• The Texas Midwifery Board should not be moved to the Department of Licensing and Regulation. DSHS is best equipped to regulate health care professions. The move will eliminate rule-making authority of the Midwifery Board, an ability crucial to continually improving safety and maintaining best practice standards.
• In the past, the Sunset Review Commission has rejected the idea of moving the Texas Midwifery Board to the Medical Board or the Board of Nursing. These are not viable alternatives since Licensed Midwives are not doctors, nurses, or physician assistants. They are unique health care professionals.
For the section “Any Alternative or New Recommendations on this Agecy:
• ACOG/TCOG have stated in their comments that there is a conflict of interest due to Licensed Midwives holding the majority on the Midwifery Board. However, doctors hold the majority on the Medical Board and nurses hold the majority on the Board of Nursing. During the last Sunset Review, it was the Sunset Review Commission that chose to give midwives a majority on the Board since other Boards at DSHS and around the country have practitioners from that profession as the majority on the Board.
• ACOG/TCOG have stated in their comments that “lay midwives” should have to comply with ACME standards and take the AMCB exam for certification. First, Licensed Midwives are not “lay midwives”. The Texas Midwifery Board already requires standardized education for Licensed Midwives as well as the NARM exam, a 350-question, eight-hour comprehensive midwifery exam. NARM is accredited by the National Commission for Certifying Agencies (NCCA) which is the same accredits ACME. The requirements recommended by ACOG/TCOG are for nurse-midwives with an expanded scope beyond that of the Licensed Midwife and are not specialized for providing care in out-of-hospital settings. These standards would put over 200 midwives out of business, harming Texas’ economy and reducing access to maternity care for thousands of Texans.
• No changes are currently needed to the Texas Midwifery Board and revisions should be discussed during the 2016-2017 review.
Comments must be received by June 30th!
Please contact me with any questions or comments. You can also copy and paste your comments into an email and forward to me for our records if you are willing.
Thank you for your support!
Brielle Epstein, LM, CPM
Legislative Chair, Association of Texas Midwives
Midwife Adviser, Texans for Midwifery