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Board of Direct Entry Midwifery - Amended Fiscal Impact Statement & Extended Public Comment Period to June 4

Thursday, May 09, 2019

The Health Licensing Office has amended the Statement of Need and Fiscal Impact for direct entry midwifery proposed administrative rules. The amendments relate to the public, consumers and small businesses. An agency may amend a filing if the agency developed the fiscal impact statement with the assistance of an advisory committee.
Further, public comment has been extended until June 4, 2019, at 5 p.m. to allow interested parties to provide additional “data and views” regarding the proposed rules and the fiscal impact statement.
The Board of Direct Entry Midwifery is expected to review and consider all public comment at the June 27th meeting and adopt final rules on July 18th.  It is anticipated that rules will become effective on September 1, 2019.
All public comments must be received by June 4, 2019, at 5 p.m. and can be submitted to:
Samantha Patnode
1430 Tandem Ave, Suite 180, Salem, OR, 97301 or
If you have additional questions, please contact Samie at (503)373-1917 or at the email address provided above.
Board of Direct Entry Midwifery Chapter 332, Division 10 through 40. “Amended Statement of Need and Fiscal Impact” 
Amendment to section 1 - Cost of Compliance:
If a consumer must transfer care to hospital from a home birth with a licensed direct entry midwife it will likely be an increased cost, to that consumer depending on insurance coverage, deductibles and copayments. It costs an estimated $30,000 for a vaginal delivery and $50,000 for a Cesarean section in which commercial insurers pay out an average of $18,000 and $28,000. Costs include but are not limited to medications, hospital costs, doctors’ fees, newborn care, blood work, surgery supplies and labor room.
Exact costs are not quantifiable because of the variable involved – consumer choice, various health plans/copays, various times at which care may be transferred which would impact the length of prenatal care with a provider or possibly emergency care received, whether a specialist (maternal/fetal medicine) is needed or an OBGYN, whether additional pregnancy or labor conditions would surface or be avoided due to a change in care to a doctor, hospital, or traditional midwife, whether LDM supportive care is provided, etc.
Assuming a traditional midwife is considered the public, a mother could transfer care to a traditional midwife; there is no regulatory oversight of traditional midwives in Oregon, except for the client disclosures they most provide, and traditional midwives are prohibited from using legend drugs and devices. Thus, a transfer of care could financially benefit a traditional midwife. The cost for a traditional midwife will likely be less than hospital birth. The cost for a traditional midwife assisted birth is unknown.

Rule amendments required more consultation for certain indications. If licensed direct entry midwifes (LDM) are considered the public there may be fees associated with consulting other providers who have expertise with the indication. Consultation may happen in person, by
telephone or other means available. The cost for consulting may vary by type, provider, length of consult, insurance coverage, etc. and is not quantifiable. This also may affect LDMs if the consulting provider recommends transfer of care to another provider and transfer occurs, costing LDMs approximately $2600 for care for the entire pregnancy including postpartum and newborn care. Consumers may also be affected by consultation fees depending on how charges are quantified, if any, and passed on to clients.
Amendment to section 2 - Cost of Compliance:
If a mother chooses to transfer care to a traditional midwife, the traditional midwife is likely a small business owner with a small practice and client base, then the traditional midwife would likely see a positive impact. The cost for a traditional midwife is unknow so the fiscal impact cannot be determined.
Generally, LDMs are sole proprietors with small businesses in the practice of midwifery. There are approximately 80 LDMs in Oregon. If indications arise that require transfer of care, including twins and postdates (past 43 weeks) pregnancies, whether to a traditional midwife, emergency services or a hospital, the small business may see a negative impact.  Cost for total pregnancy is approximately $2600 depending on insurance, fee for service payments by Oregon Health Plan or private consumer payments. If the LDM provides supportive care to the client following the transfer of clinical care, then the impact on the small business would likely be  less.
LDMs usually work or own small businesses, where consulting is required, there may be charges made to the small business as discussed above. These costs are not quantifiable and would depend on the type of consultation, provider, length of consult, insurance coverage, etc.
Amended Fiscal Impact and Proposed Rules
Clean copy of proposed rules
Rules Schedule and Reference List

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