Rigid Physician Supervision Requirements Impede Care for Home Birth Families

In regard to DHEC’s proposed new regulations revisions for hospital based physician approval for all moms planning home delivery, the following are my concerns about the restrictions. . Learn more about DHEC proposed new restraints at: http://www.scnacpm.org/call-to-acti...

502. Prenatal Care

"A. The midwife shall, upon acceptance of a woman for care, require her to have two (2) visits with a physician, with obstetric admitting privileges at a South Carolina hospital. One of these visits must be in the final six (6) weeks of pregnancy. A physician shall make a written determination that the planned birth is low risk. The midwife shall make entries in the patient’s record of the physician visits."

These proposed revisions have numerous problems:

1) If DHEC is going to provide a regulation, they should also provide the means with which to comply with the regulation. I have personally made contact with every known member of the DHEC OB Task Force medical offices and Dr. Bullard, DHEC staff OB. None of them were able to provide the services proposed in the regulation revision.

I have contacted my local health department Family Planning and WIC offices and they were staffed by APRN's who would not qualify under the conditions of the proposed regulation.

The current regulation states: "1. Required Visits. The midwife shall, upon acceptance of a woman for care, require her to have two visits with a physician, community health center or health department. One of these visits must be in the final six weeks of pregnancy. The midwife shall make entries in the patient's record of the physician, health center, or health department visits."

While the current allowance of maternity "HEALTH DEPARTMENT VISITS" for women desiring Licensed Midwife care, may not currently be the only option for some women in SC, at least the current regulation allows for clinic visits so that all SC women have access care. If the proposed regulation revision is adopted, DHEC will not be ensuring that the public needs are met.

Requiring women to find physicians with OB admitting privileges is not a reasonable rule or regulation.

2) I have found a small percentage of hospital based physicians who would both qualify and be willing to provide the proposed regulations revisions. But on every occasion their affiliated hospital disallowed them from providing the service.

Although EMTALA mandates ( The Emergency Medical Treatment and Labor Act) that a public hospital accept all pregnant women in labor, it does not require that the hospital provide prenatal risk assessments. If DHEC wishes consumers to be able to find a hospital based physician, the burden of the regulation MUST BE ON THE HOSPITAL. If it is the belief that a collaborative arrangement between a physician with OB admitting privileges and a Licensed Midwife is the best interest of the public (there is no evidence to support this theory), then DHEC should require the hospitals to supply the care. It serves no purpose to require the consumer or the Licensed Midwife to find services that do no exist. The burden of regulation must start with the hospitals.