A Public Letter to the Medical Board of California

Dear CALM supporter:

Please see below a DRAFT letter for your review. To indicate your organization's willingness to support this letter, please complete the form at the end of this letter.

Once the list of signatories has been finalized, we will send you a final version for circulation. Until then, please do not share.

Thank you,

The CALM Legislative Team

DRAFT: A Public Letter to the Medical Board of California

Denise Pines, President, Ronald H. Lewis, V.P., and Members of the Medical Board of California (MBC)

The Medical Board of California
2005 Evergreen Street, Suite 1200
Sacramento, CA 95815

Dear President Pines, Vice-President Lewis, MBC Members, and MBC Staff:

This is a joint letter of opposition from the California Association of Licensed Midwives, California Families for Access to Midwifery and others expressing our objections to proposed legislation that would restrict the reproductive rights of Californians by limiting the scope of practice of licensed midwives (LMs) under California law.

In particular, the undersigned organizations oppose legislation that would restrict LM scope of practice with respect to individuals who choose access to vaginal birth after cesarean section (VBAC).

Such restrictions undermine the fundamental principle of patient autonomy, mandating that clients who are seeking an alternative to obstetric-based care transfer to physician-led care, even if such care and the costs associated with it prove to be unnecessary.

Given the widespread practice of hospitals, insurers, and physicians refusing to offer VBAC services in the majority of cases, denying women care from an LM will have the unintended effect of forcing them to undergo repeat cesarean surgery, regardless of whether it is medically indicated or not.

So-called VBAC bans have no basis in the evidence. In fact, such bans are in violation of the American College of Obstetricians and Gynecologists’ guidelines with regard to both VBAC and patient autonomy in the context of informed decision-making.

In addition, cesarean surgery carries three times higher risk of maternal death than vaginal birth, as well as increased risk of maternal morbidities, including infection; injuries to the bladder and other organs; postoperative pain; and difficulty nursing, as well as higher short term and long-term risks such as rehospitalization and life-threatening placental conditions in future pregnancies.

Further, forcing women to undergo repeat cesarean surgery will have a disproportionate impact on communities of color, which experience significantly higher rates of maternal mortality and other disparities in care.

Using state law to ban access to VBAC services by LMs would force California’s birthing citizens to assume undue risks to their life, health, and bodily autonomy, and would undermine our state’s longstanding commitment to reproductive and racial justice.

For the above reasons, we are calling on the MBC to forgo legislation banning VBAC services from LMs and instead promulgate a rule that facilitates comprehensive informed consent for LM clients, as MBC staff agreed to do nearly three years ago.


Respectfully submitted,

Rosanna Davis, President, California Association of Licensed Midwives (CALM)

Californians for the Advancement of Midwifery (CAM) Board of Directors

Teresa Yu. President, California Families for Access to Midwifery (CFAM)



Along with this letter, we submit links for the following documents:

Jen Kamel, VBAC Facts

Federal Trade Commission

CHCF California's Midwives: How Scope of Practice Laws Impact Care

CMQCC Study on C-section and VBAC in CA Hospitals

Safriet, Barbara J., "Closing the Gap Between 'Can' and 'May' in Health Care Providers' Scope of Practice: A Primer for Policymakers" (2002). Faculty Scholarship Series 4422.

Pascucci, Cristen, "Why Are We Asking Doctors If Women Should Have Midwives?" Birth Monopoly.

Mapping Midwifery PLOS ONE Study by the Birth Lab:

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