News

Request that the midwives on the Board focus on midwifery; 8/2025

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Published Date

August 4, 2025

Dear Executive Director Burke and Chairperson Herman,

I have been an active, practicing home birth midwife in Massachusetts for 25 years. My livelihood is now covered under the actions and regulations made by the Massachusetts Board of Registration in Midwifery. I respectfully request this letter be read at the next Board meeting to develop discussion points so that the public can hear and understand the Board’s perspective.

While not in MA, I understand that midwives in many states across the U.S. were persecuted and prosecuted for home birth midwives. I understand that this effort to license MA home birth midwives was with good intent.

1. Could the Board be curious about how home birth midwifery in MA is working now? MA home birth midwives have been working with Massachusetts Midwives Alliance (MMA) practice guidelines since the 1980s. http://massmidwives.org/for-midwives/forms-and-documents/ We have well-developed practice guidelines that, before COVID, had been reviewed regularly by actively practicing MA home birth midwives. Could the Board review the MMA practice guidelines as a way to develop rules and regulations from a bottom-up approach vs. a top-down approach? Is there a way to codify what’s currently working vs. create mandates and restrictions on choices for birthing bodies? Please note that pages 31 and 32, Appendix 1: Transfer Criteria of the MMA guidelines include transfer criteria during pregnancy, during labor, during the postpartum period and for the newborn. But most importantly, throughout the MMA guidelines, the emphasis is on bodily autonomy, informed decision-making, birthing person as ultimate decision-maker…”When a primary care provider decides that a (sic) woman and/or baby must be transferred, the family will participate in the decision-making process and will be given a full explanation of the immediate problem and reason for the decision.” If MA home midwifery care has had the best outcomes, can we use the existing MMA practice guidelines for rules and regs?

2. MA home birth midwives have been practicing under the auspices of bodily autonomy and choice. Every MMA guideline ends with: “If the client declines any recommended (prenatal) care in the presence of variation, the midwife should document client education and discussion of why the care is recommended and obtain signed evidence of informed choice.” Please see the attached Group Beta Strep guideline. The emphasis is on “offer” and “discuss” and not “not allowed” and “prohibited”. Could the Board develop rules and regulations that are less about having “teeth” to punish home birth midwives and home birthing families for not following the government rules and include provisions such as the above that include choice, bodily autonomy and informed consent/refusal and non-abandonment of care?

3. I’m assuming the law to license midwives was intended to increase home births and increase home birth midwives. Last month’s discussion included “cardiac disease” as an immediate transfer of care item. Board member Kristin mentioned a case of a client who had an unrelated cardiac issue and had had 2 home births. If “cardiac disease” were to be put in the rules and regulations, this client, who has had home births, would no longer be allowed to have a home birth in MA with a MA licensed midwife. Adding a government regulation that suddenly makes a birthing body illegal to have a home birth may not have the intended consequences; it may not compel this birthing person to go to the hospital for their next birth. It may compel the birthing person to bypass this restriction on their body by, for example, crossing state lines, renting a room in another state or flying in a care provider to get the midwifery care they want and has had in their previous pregnancies. Or they could have an unassisted birth.

“Women seeking alternatives to the hospital system are increasingly in a position of not having access to midwife-supported care. This can lead women to plan a birth ‘outside the system’, without the presence of a health professional (Jackson et al., 2012; Rigg et al., 2018)." “Birthing Outside the System: The Canary in the Coal Mine by Hannah Dhalen, Bashi Kumar-Hazard and Virginia Schmied. Can the Board develop rules and regulations with an emphasis on increasing or embracing home midwifery care vs. denying access to care/restricting midwives from attending previous home birth clients who would become illegal under the regulations?

4. Could the rules and regulations be made from a place of “most common” scenarios vs. “dead mom/baby” scenarios? Can the discussion about birthing bodies’ choices and the midwives who support them come from an increases access to home birth midwifery perspective? Recounting “dead/damaged mom/baby” scenarios is a form of emotional manipulation. Recounting worst case scenarios can be misused to pressure individuals into making decisions they might not otherwise choose and is counterproductive to fostering respectful and open dialogue. It can escalate emotions, create defensiveness, weaponize safety, infantilize birthing people and hinder the possibility of meaningful communication about sensitive topics.

5. On that note, is the Board developing rules and regulations via vote or consensus? Whose voice counts the most? I know home birth midwives have been trained to be quiet, stay under the radar, don’t make waves, don’t push back; but can the public hear more opinions during the public Board meetings from the 5 home birth midwives on the Board? We know that our culture is racist and misognistic and anti-midwifery. We know that the U.S. maternity industrial complex weaponized "safety" and prosecuted Granny Midwives out of existence. We know that ACOG and AAP have been organized around a white, male, power gaze and maternity studies have been done looking at metrics on bodies without considering impact on the human. I believe midwifery rules and regulations should be from actively practicing home birth midwives and not from the studies and culture and organizations and opinions that are not run by home birth midwives, that are not home birth midwifery focused, that are not supportive of home birth, from folks who have never attended a home birth. Can the Board develop the most open, welcoming, midwifery-model-of-care-centered and human-centered rules and regulations in the nation?

Sincerely,

Joyce Kimball, MBA, CPM, ADN, RN, LM