RE: Proposed Rule 26P029 — Licensure of Freestanding Birth Centers
Dear Commissioner and Rulemaking Staff,
Right for Vermont Foundation submits this comment on proposed rule 26P029 governing the licensure of freestanding birth centers. We write in strong support of the underlying goal of S.18, to expand maternity care choice in Vermont, and we urge the Department to revise the proposed rule so that it does not undo, through licensing costs and compliance burdens, the access that the legislature just voted to create.
We ask the Department to reconsider three specific provisions before finalizing this rule:
1. Mandatory CABC accreditation, maintained indefinitely, is not necessary for licensure.
2. Stacking a full state inspection on top of CABC accreditation is redundant.
3. Blanket 24-hour on-site, two-provider staffing requirements should be replaced with 24-hour on-call coverage by one licensed clinician.
