June 21, 2019
Open Letter Concerning Assembly Bill A364B:
Village Birth International (VBI) is a community-based organization and 501c3 nonprofit dedicated to supporting community-led doula care for families in Upstate New York. We have worked for reproductive justice and improving maternal health for families in Onondaga County since 2010. Over the last year, VBI has actively engaged the New York State Department of Health to address disparities in maternal outcomes by addressing the programmatic needs of implementing and developing Medicaid Reimbursement for doula services. These programs directly impact the doulas and families we support every day.
We are writing today to oppose Bill A364B in its current presentation. We recognize the need for training, competency, and mentorship for any doula seeking reimbursement for serving birthing people receiving Medicaid. Certification can ensure that core competencies and principles of practice for doulas enrolled in Medicaid reimbursement programs are equipped to serve families of color and low-income communities. This bill is part of a larger initiative to address high maternal mortality and morbidity rates particularly for African American families. Community-based doula and midwifery care are solution driven models proven to improve outcomes. African descended midwives and birth workers have practiced for generations offering supportive care which centered community needs and self-determination. The regulation and restriction of all doulas in NY State, and implementation of certification policies without incorporating community-based doula models, erase not only this legacy but the potential to save lives and support families with the dignity and culturally sensitive reproductive care they deserve.
This bill seeks to standardized reimbursement services for doula care under the Medicaid pilot to increase access to doula services, however it does not address the quality of those services in its current language. This bill will also severely regulate and restrict any doula practicing in NY State. Access to care is insufficient in addressing health disparities particularly for birthing people of color who face not only physical barriers including income inequality in birth, but a full range racial and gender-based inequality in healthcare and throughout their daily lives.
In Syracuse, our collective of doulas are mostly African descended women. Many are certified, skilled, and educated by traditional models of apprenticeship and community centered education. The care they offer goes beyond birth work and provides a full scope of support that impacts and improves the lives of their community. Some are born in Syracuse; however, many are African refugees with English as their second language. They are skilled birth workers, helping to mitigate the effects of resettlement, language barriers and bridge cultural practices in pregnancy, birth, and postpartum care. Doulas are invaluable leaders within their community helping families connect to resources that improve their quality of life and navigate the medical system to ensure people birth with support and confidence. Many doulas in Syracuse and across New York State will continue to serve families without Medicaid reimbursement. We need to protect and ensure they can continue this important work without jeopardizing their ability to practice and support their communities.
• VBI is concerned with the language of Bill A364B. “Only a person certified under this section shall be authorized to use the title “certified doula”. Doula care is a longstanding tradition for communities, specifically communities of color, who collectively gather to support one another during reproductive transitions. One agency laying claim to how all doulas will be titled negates the varied ways doula care is practiced cross -culturally, offered to a variety of families and how those families can access this life saving skill. Doulas practice in NY State and nationally from varied backgrounds and certifications based on who and how they will serve families as individuals. If the state department intends to ensure doulas receiving Medicaid reimbursement are certified, then the bill should reflect language stating certification and its requirements specific to Medicaid Reimbursement. Regulation stating who can use the title of ‘’certified doula” generally is extremely problematic and detrimental to all individual doulas and birth workers across the state of New York.
• The definition of “certified doula” in the current bill states any individual seeking Medicaid reimbursement must be certified with an educational program “that is determined to be in accordance with the commissioner’s regulations”. VBI is concerned with the generalized language of this section. Families receiving Medicaid can be the most at risk for poor outcomes in birth. In order to serve effectively, individual doulas seeking to support low income families should be equipped with a full range of community-based doula care core competencies and principles of practice. Certification and educational policy must clearly define a human rights approach to doula care that centers not only barriers in social determinants but also reproductive justice in birth including access to care, quality of maternal health care, and culturally respectful support services that incorporates a health and race equity framework.
• The language of Bill A364B describing that the “character” of doulas and that individual doulas “be of good moral character as determined by the department” is a concern. What are the standards of “good moral character” as stated by this department? Within any service and service provider role, standards of practice and expectations should be clear and concise so that interpretation is not left open for individual review. We are concerned that subjective thinking and implicit bias will impact judgement in determining who is “good”.
• VBI is also concerned with the Examination requirement. Additional barriers like an entrance exams, large amounts of paper work and fees will deter, specifically, many of our community-based doulas. Doulas and families overcome many obstacles to provide and access doula care including transportation limitations, income, and English as a second language. We need to ensure that we are eliminating barriers not creating additional ones.
• VBI recommends removing the fee as this will create another barrier to reimbursement.
To ensure officials are creating policies that are reflective of the needs of their constituents and the communities they seek to improve, it becomes imperative that a full understanding of the varied ways doulas can provide care and the community-based standard of certification that is congruent with the needs of birthing people most effected by the maternal health crisis in our state. We urge you to reconsider the current generalized language of this bill while considering specific practices and certification models that ensure doulas are equipped with the tools needed to serve families receiving Medicaid in our state.
Thank you for your continued effort to support and improve health outcomes for families across New York State.
Asteir Bey RN, IBCLC Village Birth International, Co-Director firstname.lastname@example.org
Aimee Brill, CD Village Birth International, Co-Director email@example.com
Cc: Assemblywoman Amy Paulin, Sponsor; Senator Jessica Ramos, Sponsor; Assemblyman Richard Gottfried, Co-Sponsor; Assemblywoman Galef, Co-Sponsor; Assemblywoman Jaffee, Co-Sponsor; Assemblywoman Rosenthal, Co-Sponsor; Assemblywoman Cook, Co-Sponsor; Assemblywoman Seawright, Co-Sponsor; Assemblywoman Arroyo, Co-Sponsor; Assemblyman Blake, Co-Sponsor; Assemblywoman Dickens, Co-Sponsor; Assemblywoman Pichardo, Co-Sponsor; Assemblywoman Thiele, Co-Sponsor; Assemblywoman Solages, Co-Sponsor; Senator Biaggi, Co-Sponsor; Senator Kaplan, Co-Sponsor; Senator Gaughran, Co-Sponsor; Senator Krueger, Co-Sponsor; Senator Rivera.