FW: proposed rules for demonstrating project on freestanding birth centers
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Kitty Ernst
Sep 28, 2010, 3:21:41 PM9/28/10
to birthc...@googlegroups.com
I have been working on the review of these regs for the
past 2 weeks. I had more than 12 pages of comments when I was half-way
through. I decided that it was better to propose an alternative for the
demonstration project than to deal with inappropriate rules that are
misdirected. Attached is background information and my suggestion for
delay of finalization of proposed rules for an interim alternative approach
which would enable final rules based on experience and
evidence.
Kitty
Kitty Ernst, CNM,
MPH, DSc (hon)
Coordinator for
AABC Consulting Group
Mary Breckinridge
Chair of Midwifery
Frontier School of
Midwifery and Family Nursing
1207 Perkiomenville
Road
Perkiomenville, PA
18074
Tel: 215 234
9179
From: Kitty Ernst [mailto:kitty...@gmail.com]
Sent: Tuesday, September 28, 2010 2:42 PM
To: 'dph....@illinois.gov'
Cc: 'kate...@birthcenters.org'
Subject: proposed rules for demonstrating project on freestanding birth centers
Dear Susan Meister,
I really apologize
for this late entry into deliberations of your efforts to establish rules for
the implementation of the Freestanding Birth Center Demonstration
Program
under the
Alternative Health Care Delivery Act to be licensed by the Illinois Department
of Health.
As discussed with
you on the phone today, I have attached my thoughts on trying to comment on
these rules and, although too late, proposed an
alternative
for the purposes of
providing oversight and evaluation of this exciting and important
project.
Please
understand that my proposal is for the limited purposes
of the demonstration only and is in no way intended to
supplant the need for final rule-making
under your
authority.
I appreciate that
you will forward it to Bill Bell for consideration by whomever may be
interested.
Since I am unknown
to you, I have also attached my CV for your information.
Thank you again for
speaking with me. Please do not hesitate to contact me if I may be of
further assistance.
Kitty Ernst, CNM,
MPH, DSc (hon)
Coordinator for
AABC Consulting Group
Mary Breckinridge
Chair of Midwifery
Frontier School of
Midwifery and Family Nursing
1207 Perkiomenville
Road
Perkiomenville, PA
18074
Tel: 215 234
9179
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