I am extremely concerned about the Midwifery Rules Revisions. The latest draft of proposed rules is extremely unsafe and impractical. It will endanger lives of mothers and babies. It will work against collaborative care for families who chose homebirth. It will increase unassisted homebirth. These negative effects will reflect badly on our state and on ADHS.

The following issues MUST be changed in the final draft:

1) It will be a Class 6 felony for midwives to administer lifesaving medications
that they are currently licensed to purchase, carry, and administer. These medications are the standard of care worldwide. Midwives must be allowed to administer these medications.
2) Parents do not have the right to refuse testing or treatment for mother or
baby that they are opposed to. If they do, they are no longer able to be attended by a midwife. This is a severe parental rights violation.

There are numerous other issues with the draft. These are a few of them:
• Midwives will be required to call EMS BEFORE they can handle emergency situations. This will drastically endanger lives because time is critical in some complications and stopping to make a phone call would be inappropriate and negligent.
• There is a required call to the closest hospital at the beginning and end of every labor to alert them that a woman is in labor at home. This is a violation of HIPAA, and it will increase liability and work for hospital staff. This will promote more discord in the birth community.
• All consultations are required to be in writing, which most doctors don’t have the time and won’t be willing to provide. A documented verbal consultation is the current reasonable standard.
• All consultations are required to be with an OB when it may be more prudent for a mother to consult with another type of specialist such as a cardiologist, neurologist etc. CNM’s should be added to the list of providers that can be consulted with.
• There is an increased amount of paper work and reporting to the state that will burden both the midwives and the state.

Thank you for your time and concern. I hope that you will repair these issues so
that families in Arizona will have freedom and safety in their birth choices.