FOR IMMEDIATE ACTION! Recommended Response to Rules.

[Gayle Riedmann]

Dear Birth Center Supporters,

FOR IMMEDIATE ACTION: The Illinois Birth Center Task Force has
reviewed the PROPOSED RULES for the Birth Center Demonstration Project
as posted on August 20, 2010 for 45-day Public Comment.

You can view the PROPOSED RULES at Illinois Register.BirthCenters (go
to page 12012).
or cut and paste http://cyberdriveillinois.com/departments/index/register/register_volume34_issue34.pdf

It is VERY IMPORTANT that you use this opportunity to have an impact
on the viability of establishing Birth Centers in Illinois.
Your response MUST BE POSTED by OCT 1, 2010.
Send your Public Comment to:

Susan Meister
Illinois Department of Public Health
535 West Jefferson St., 5th Floor
Springfield, Illinois 62761
217/782-2043
e-mail: dph....@illinois.gov
PLEASE CC YOUR COMMENTS TO birthcente...@hmprg.org

The Birth Center Task Force has prepared our list of recommended
changes (see document under "Files" on this group), categorized by
those proposed rules that we believe are most critical ("Highest
Priority) to amend or delete, and those that are of lower priority.


PRIORITY: See page 12071; 265.2600 c SUBPART B CONSTRUCTION
STANDARDS:
The detail of these construction requirements are due to the fact that
IDPH has designated a Birth Center as an "Ambulatory Health Care
Occupancy". This status under the National Fire Protection
Association's Life Safety Code should only be applied in situations
where patients are rendered incapable of escaping during a fire, and
is usually reserved for Ambulatory Surgical Centers where anesthesia
is used.

The preferred facility designation would be a "Business Occupancy",
which would eliminate unnecessary and costly construction (e.g. width
of hallways, sprinklers) and operational (e.g. quarterly fire drills)
requirements. At a minium, please address that issue, as the spirit
and intent of Birth Centers is to minimize the use of interventions
that would not permit a mother to physically be able to leave if a
fire broke out. Specifically, ask that Birth Centers be designated
Business Occupancy based on models used in 34 states.

The highlights of the other recommended changes are ;

-fee for licensure:
-admission criteria language
-construction requirements (applicable if Surgical Center licensing)

Have questions? e-mail birthcente...@hmprg.org

We thank you for your advocacy on behalf of the women and their
families who will benefit from the availability of Birth Centers in
Illinois.

Gayle Riedmann, CNM
Chair, Illinois birth Center Task Force