UPDATE, December 2013:
Despite weeks and weeks of resolution attempts, NFRMC refuses to recind their policy, stating that these regulations are being put into place "to protect mothers." We need to remind them that we, as women and mothers, are more than capable to make those decisions for ourselves; we do not want or need their protection. We want, need, and deserve the respect and autonomy to make our own medical decisions, including choosing who we want to support us during our pregnancy and birth experiences.
In addition to the infringement on mother's rights, these regulatory policies are clearly a restriction of trade, aimed only at doulas. As defined by their Dependent Health Practicioner guidelines (the guidelines by which they are trying to enforce doula regulation), other non-medical DHPs are NOT required to undergo any such registration, screening, or regulatory policy or procedure, including but not limited to massage therapists, private therapists, etc.
HCA (the governing organization of NFRMC) maintains an Ethics Line for obtaining guidance on an ethics or compliance issue or reporting concerns. We [HCA] encourage the resolution of issues at a local level (supervisor, another member of management, Human Resources Manager or Facility Ethics and Compliance Officer) whenever possible. However, individuals may always contact the Ethics Line at 1-800-455-1996.
Because we have exhausted our local contacts to resolve the situation (NFRMC representatives are no longer honoring our requests for information and have ceased all communications), we urge you to call the HCA Ethics Hotline to voice your concerns. It is available at all times, and you can choose to remain anonymous.
It has come to our attention that North Florida Regional Medical Center has recently begun restricting who women can have support them during childbirth. Specifically, they have implemented regulations that require doulas – independent, non-medical support persons hired by women from pregnancy through the postpartum period - to complete an extensive registration process before they can accompany their clients to this hospital, including but not limited to a background check, immunization record, TB testing, and HIPPA documents, upon penalty of expulsion if the registration requirements are not met. This type of registration and restriction is strictly in violation under the CMS and Joint Commission Inclusive Visitation Requirements.
As of January 18, 2011, in order to comply with the revised Conditions of Participation, hospitals participating in the Medicare-Medicaid Program must:
Adopt written policies and procedures concerning patients’ visitation rights, including any clinically reasonable and necessary restrictions or limitations on visitation;
Provide notice to patients or their support persons (where appropriate) of their visitation rights, including the right to receive visitors designated by the patient. A patient may designate virtually anyone -- a spouse, domestic partner (including a same-sex domestic partner), another family member, or a friend. The notice must also advise of the patient’s right to withdraw or deny consent at any time;
Ensure that all visitors enjoy full and equal visitation privileges consistent with the patient’s preferences
As of July 2011, in order to comply with these revised standards, hospitals must:
Respect, protect, and promote patient rights;
Allow a family member, friend, or other individual to be present with the patient for emotional support during the course of stay;
Allow for the presence of a support individual of the patient’s choice unless the individual’s presence infringes on others’ rights, safety, or is medically contraindicated. The support person may or may not be the patient’s surrogate decision-maker or legally authorized representative.
A doula was recently forced to leave a laboring mother at the hospital when the doula was expelled due to her “unregistered” status. The mother and father clearly stated that they wanted the doula present, but the hospital staff forced her to leave against the parents’ request. The doula had previously spoken to at least two different staff members in NFRMC’s Labor & Delivery unit to clarify whether she needed to register; the mother had also asked her care provider; and in every instance, they were told the doula had express permission to attend the birth. There was no mention of a mandatory registration process to be completed prior to the admittance of the mother to the hospital.
We are very concerned that an ill-communicated and misguided administrative policy was taken to such an extreme as to separate a mother in labor from the person she independently hired to support her through it safely. In fact, the mother was refused medical care for several hours while the discussions were taking place prior to her doula being forced to leave.
Furthermore, in 2012, Hodnett et al. published an updated Cochrane review on the use of continuous support for women during childbirth. Overall, women who received continuous support were more likely to have spontaneous vaginal births and less likely to have any pain medication, epidurals, negative feelings about childbirth, vacuum or forceps-assisted births, and C-sections. In addition, their labors were shorter by about 40 minutes and their babies were less likely to have low Apgar scores at birth.
The researchers also looked to see if the type of support made a difference. They wanted to know — does it matter who you choose for your continuous support? The best results occurred when woman had continuous labor support from a doula – someone who was NOT a staff member at the hospital and who was NOT part of the woman’s social network. When continuous labor support was provided by a doula, women experienced a:
31% decrease in the use of Pitocin*
28% decrease in the risk of C-section*
12% increase in the likelihood of a spontaneous vaginal birth*
9% decrease in the use of any medications for pain relief
14% decrease in the risk of newborns being admitted to a special care nursery
34% decrease in the risk of being dissatisfied with the birth experience*
Evidence shows that the most important thing is for women to have continuous labor support from someone– whether that person is a nurse, midwife, partner, or doula. However, with several birth outcomes, doulas have a stronger effect than other types of support persons.
We appeal to NFRMC to draft a revised visitation policy that meets the requirements of the Medicare CoPs and the Joint Commission’s standards and to respect the right of mother's to choose who may visit them during an inpatient stay regardless of whether the visitor is a family member, a spouse, a domestic partner, or another type of visitor.
American Health Lawyers Association. "Revisiting Your Hospital's Visitation Policy."The American Health Lawyers Association. <http://www.healthlawyers.org/hlresources/PI/InfoSeries/Pages/RevisitingYourHospital%27sVisitationPolicy.aspx>
Dekker, Rebecca. "The Evidence for Doulas Â« Evidence Based Birth." Evidence Based Birth. <http://evidencebasedbirth.com/the-evidence-for-doulas/>