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Published: 18 June 2026

On April 23, 2026, the Board of Registration in Midwifery opened a voice call to the public to comment on the upcoming temporary licensure for midwives in Massachusetts. Because midwives and the public can only listen to Board of Registration in Midwifery meetings and not comment nor speak to members of the Board re: midwifery licensure, the opportunity to show up and let our voices be heard was something many midwives and the public could not resist. While this "public comment call" was supposed to be about the temporary licensure, most commenters used the space to comment about their concerns currently and for the future in the licensing of MA home birth midwives. 

Here are the words I wrote, submitted in writing to the Board and read on the public comment call on April 23, 2026:

Hi my name is Joyce Kimball. I’ve been a Massachusetts home birth midwife for 26 years. I vehemently opposed licensing Massachusetts home birth midwives as I believe the act of licensing us has done exactly what I thought it was going to do - restrict access to home birth midwifery as a profession and reduced choices and options for birthing folks in Massachusetts.

When I watched the Mass board of midwifery members vote on rules and regulations and 7 out of 8 of them chose the most restrictive, conservative, non-autonomous midwifery limits in an effort to be palatable to Massachusetts medical associations and to move the licensing forward as quickly as possible, it confirmed for me that Mass home birth midwives have been thrown under the bus.

The exclusive-to-CPMs only, Mass Chapter of NACPM, was created recently, and in direct response to pushing the licensing of MA home birth midwives through. All stakeholders are not at the Mass board of midwifery table, nor are home birth midwives the biggest influence on the Board of Midwifery. I wonder if my midwife sisters thought that the state lawyer and the ob on the Mass Board of Midwifery would speak the most and have the most influence on the rules and regulations of Mass home birth birthing bodies. 

There is no recognition on the Board of Midwifery, of Massachusetts Midwives Alliance - the Mass home birth midwives inclusive trade organization that has been in existence since the 1980s. The kind, cohesive group of MA home birth midwives, connecting and attending each others births, is no more. We have had our cohesive, supportive home birth midwifery culture stolen from us and given over to state control.

The information sent from the Mass Chapter of NACPM says that this phone call is about temporary licensure. Temporary licensure that “makes possible”:  

“Entry into formal health care system conversations”

“jobs and employed roles can begin to emerge”

“masshealth coverage is expected”

“prescriptive authority becomes accessible”

These are meaningless highfalutin words.  “Entry into formal health care system conversations” means that a few license-happy folks can talk to the mass department of public health officials about how they want to structure licensed Mass home birth midwifery.

“jobs and employed roles can begin to emerge” means that maybe 5 out of the 35 home birth midwifes in Mass will be able to work at the currently non-existent birth centers.

“masshealth coverage is expected” means that maybe masshealth will cover home birth in the future. But please know this – masshealth does not currently cover any health service in Massachusetts well enough for a solo provider to live off of. And, please, for the love of *od, we cannot take on more clients to make up the poverty-level money that Mass Health may reimburse us.  There are 70,000 births in Massachusetts every year – 69200 of them in the hospital. The average Mass home birth midwife attends 20 home births per year (800 home births per year/35 midwives). It’s not the midwifery model of care to behave like the obstetrical industrial complex of taking as many clients as possible with no continuity of care.  Mass home birth midwives will not be compensated enough by mass health or any insurance company in order to accept more than 1 or 2 mass health clients per year, at a loss.

Just fyi, the birth center in western mass takes mass health. 60% of their clients are on mass health. The western mass birth center does 100+ births per year. They received, appropriately I think, close to 1 million dollars from the state to stay open; and the birth center may close soon because it does not get reimbursed enough from Mass Health and insurance.  The “masshealth coverage is expected” statement is a red herring.

“prescriptive authority becomes accessible” means that we will need to get and pay $300 - $400 per year for state permission to carry the anti-bleeding medications we currently carry to care for our clients.

Mass NACPM writes that they are wanting the Board of Midwifery to “bend” to the Midwifery Model of Care and that this molding of the licensure will happen if midwives are “engaged” and “involved”; that there are “opportunities to shape what’s next”. Bull. Do birthing folks know that board of midwifery members do not receive correspondence from constituents or other midwives? That midwives observing the board of midwifery meetings may not speak or be seen or provide any feedback to the board of midwifery? That emails to the board of midwifery are usually not answered and if they are answered, are answered by state employees? We are not allowed to contact board members directly. Board members may not speak to each other between meetings. Board meetings are stilted and overtaken by the lawyer and ob. Heck, with 26 years of experience and attending over 1200 births, I’m not allowed to be a Board of Midwifery member because my Certified Professional Midwife certification has been deemed less than and not allowed on the Board.

It’s over. We are licensed. We have a board of midwifery that ices out input, is stiff and formal and quiet and has already started to over-regulate us. We have had autonomous midwifery taken from us in exchange for a piece of paper that says that we can do what we’ve been doing for the past 50 years but only if we follow what the state says. And we will be punished if we don’t follow the state’s rules. The system has won. The humans have lost.

I agree with every specific recommendation in the Mass Midwives Alliance letter.

I sure would love to see my midwife sisters on the board hold firm and never let go of autonomous Midwifery Model of Care. Only 9 states in the U.S. have no restrictions on abortion. I hope Massachusetts can be the state that has no restrictions on home birth midwifery.

My only personal ask is that we keep the spirit and provision in the rules and regulations that with documented informed choice, birthing folks can choose to accept or decline any provision in the statue. Protect the Midwifery Model of Care. Protect birthing peoples’ choices.

Thank you.

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Published: 24 October 2025

To:

Fr: Joyce Kimball

Dt: October 24, 2025

Please share the following/attached letter with the Board of Registration in Midwifery members before the next meeting.

I have already sent 2 well-researched, annotated letters to the Board of Registration in Midwifery – 1 letter in August 2025 and 1 letter in September 2025. This letter comes from my heart, a MA home birth midwife with a 25 year history of attending continuity of care home birth clients who fully express their body autonomy in their birth choices. 

I was hopeful when I attended the in-person Board of Midwifery meeting in October 2025. We now have a Board positions filled. The Board members were saying comforting words such as “this law is about increasing access”, “the draft of the rules and regulations has a component for individual choice” and “the Board is focused on codifying the Midwifery Model of Care”. Lovely sentiments.

Then the yellow flags started.

• the Commissioner is the person that will make the final decisions about the rules and regulations.
• The Board is creating rules and regulations based on the “norm” to make the rules and regs move as quickly as possible through the process.
• The informed choice provided by home birth midwives to folks wanting a home birth after cesarean (HBAC) will no longer be good enough. Folks wanting an HBAC will need to have an informed choice discussion with ob/gyn or MFM – care providers that have never attended or seen a home birth.
• Some board members didn’t know how to create their own scope of practice and informed choice documents and will use these rules and regulations to practice the rules vs. practice to the client.
• Some board members seemed surprised that an ob/gyn or MFM could be coercive or threatening or biased and suggested that clients and midwives should report providers that behave badly.

Unfortunately, terrifyingly, providers in the U.S. maternal industrial complex - ob/gyns and MFM doctors - groom, terrorize, and frighten birthing people; not all ob/gyns or MFM doctors; but enough.

More than 30% of birthing folks come through the maternal industrial complex birth process reporting not being listened to, yelled at, told to be quiet, frightened, threatened, physically held down, and told that their baby will die if they don’t do what the doctors tell them to do. Check out Dr. Rebecca’s birth trauma at UMASS Memorial and how the complaint was handled. https://www.babiesincommon.com/show/item/32-filing-a-complaint-after-birth-trauma-with-rebecca-zanconato-md. I filed a complaint with the Board of Medicine when I watched an ob/gyn manually tear a birthing person’s perineum with her hands. I received a form letter to my complaint. The ob/gyn is still practicing.

Birthing folks are discriminated against, gaslit, coerced, fear mongered, threatened and assaulted. Check out the obstetrical violence map: https://birthmonopoly.com/obstetric-violence/. Birthing folks have been told,

“It’s not about what you want, we are going to follow my plan.”

“I’m not going to take my hand out of you until you calm down.”

“If you deliver your baby at home, you and your baby will die.”

“You don’t want Pitocin? Do you want to die? Don’t you want your baby to have a mom?”

“You don’t need a birth plan; were a Baby Friendly hospital.”

“I’m not going to stop rubbing your baby.”

“I’m not comfortable with you pushing in any position than on your back.”

The idea that MA birthing folks and midwives could report harmful MA ob/gyns and MFMs to an MA authority that will actually change behavior is victim-blaming and part of obstetrical-violence culture.

The fact that ob/gyns and MFMs are the chosen folks, in these rules and regulations, to have informed choice conversations with certain folks wanting a home birth continues the violence.

The fluffy words, Midwives Save Lives, were slapped on this bill/law. These rules and regulations are being written so that home birth clients will be required to “collaborate” and/or “consult” with the U.S. maternal industrial complex – the very complex that has harmed so many birthing people; the complex that has the poorest mother and baby outcomes in the developed world. 

No one is coming to save MA home birth midwifery from being swallowed by the medical industrial complex. The commissioner has already shown his bias when the bill became law. The Commissioner doesn’t know a thing about home birth midwifery and wrote in restrictions on who can be on the Board. Someone, maybe someone from the Mass Medical Association, maybe someone from the midwifery community, called him and asked him to write into statute that certain CPMs can’t be on the Board. It’s possible that every rule and regulation that this Board writes will be re-written by a Commissioner who listens to the MA maternal industrial complex folks. He’s already done it.

For some Board members, the desire to have government permission to have CPMs work in (currently non-existent) birth centers in MA has made them choose rules and regulations that:

1. Make CPMs more palatable to the medical industrial complex and
2. align with the (non-autonomous, heavily government regulated) birthing practices of birth centers

I’m thrilled to hear that it takes the average new licensing board 3-10 years to pass rules and regulations because of all the people that need to review, comment and approve the rules and regulations. But the damage is done – Bay State Birth Coalition pushed this bill to license home birth midwives, surrounded it with feel-good legislation about lactation consultants and postpartum visits. At some point in the future, long after most have forgotten about it, this law, and its rules and regulations, will decimate the autonomous practice of home birth midwifery in MA.

My plea is that the informed choice clause 274 MR 5.03 (3) is not destroyed or reduced in the years of review that these rules and regulations will go through. To all MA midwives, please reach out to your midwifery colleagues if you need an informed choice document. Please utilize documented informed choice with your clients to the fullest extent. With the rules and regulations undercutting autonomous midwifery, please do the best you can to practice client-centered autonomous midwifery.

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Published: 24 October 2025

September 23, 2025

Dear Executive Director Burke and Chairperson Herman,

Thank you for the work you are doing in creating rules and regulations.

I am interested in attending the in-person October 16, 2025 meeting.

Could you please email or make available the documents you have been using to create the rules and regulations so that I may follow along at the October meeting?

I respectfully submit a request that, at the October 2025 meeting, the Board discuss how informed choice, informed consent and informed refusal is provided for in all aspects of “An Act Promoting Access to Midwifery Care and Out-of-Hospital Birth Options”, especially and including the Rules and Regulations.

There is a large body of evidence to show that licensing midwives has a patriarchal, racist history. Licensing midwives has been used as a white, male, Christian government weapon to keep women’s bodies monitored and in-line. Please see Columbia Journal of Race and Law. “Midwives and Pregnant Women of Color: Why We Need to Understand Intersectional Changes in Midwifery to Reclaim Home Birth” by Danielle Thompson. https://journals.library.columbia.edu/index.php/cjrl/article/view/2312 “…the racist and sexist underpinnings of the change from home to hospital birth still operate in our current birthing systems to keep women of color in hospitals and out of the midwifery profession.” I have listened to the last several Board of Registration in Midwifery meetings and respectfully request that the rules and regulations discussion be less about what the (patriarchal, racist, misogynistic) “evidence” shows (i.e. risk of death with postdates, GBS, cardiac disease, etc.) and more about a person’s right to be informed and make a choice about the care they choose.

As Hermine Hayes-Klein, JD spoke about in her Gold Midwifery Conference in 2025 “Protecting Your Midwifery Practice: Legal Strategies for Practicing with Confidence”, barriers have been created/legalized/enforced on pregnant people who desire a vaginal birth, a vaginal breech birth, a vaginal birth of multiples, giving birth at home, giving birth at a free-standing birth center, giving birth unassisted, choosing when and whether to (have an abortion).

Hermine Hayes-Klein, JD recommends a 3-step process of informing, advising and supporting, essentially encouraging and maintaining an autonomous midwifery practice. The MA law has removed this ideal process of informing, advising and supporting choice and denies the practice of autonomous midwifery care to folks you, the Board of Registration in Midwifery, will deem “high risk”. I hope that the Board of Registration in Midwifery can follow Hermine’s advice of informing, advising and supporting rather than outlawing while finalizing the rules and regulations to be placed on birthing folks and community midwifery care in MA.

Body autonomy and reproductive choice are of the upmost importance. In ACOG’s “Refusal of Medically Recommended Treatment During Pregnancy” Ethics Committee Option No. 664 (June 2016) “Pregnancy is not an exception to the principle that a (sic) decisionally capable patient has the right to refuse treatment, even treatment needed to maintain life. Therefore, a (sic) decisionally capable pregnant (sic) woman’s decision to refuse recommended medical or surgical interventions should be respected.” And “Consenting freely is incompatible with being coerced or unwillingly pressured by forces beyond oneself. It involves the ability to choose among options and select a course other than what may be recommended.”

As the Board discusses the rules and regulations to be placed on midwives and birthing bodies, especially when to consult and when to transfer, I am reminded of the “Midwife Permit” and the “Certificate of Examination” cards I saw on display at the National Museum of African American History and Culture. https://www.searchablemuseum.com/midwives-tradition-and-transition/#regulation-and-restriction

As the exhibit label says, “…midwives faced increasing restrictions on how they could practice…states passed laws that required midwives to be formally trained and certified as “suitable” by local health officials and physicians. Eventually, the practice of midwifery was restricted to registered nurses or certified nurse midwives, who were required to work under a doctor’s supervision. These regulations, in part fueled by the white medical establishment’s prejudiced views of Black and immigrant midwives, effectively eliminated the traditional lay midwife…Black midwives were also often excluded from…training programs which privileged white applicants.”

In some parts of the U.S. in the 1950s and 1960s, both midwives and women were examined by white, racist, elitist men to be deemed suitable to practice midwifery and suitable to be attended by a midwife at home. The Certificate of Examination cards say, “Name: _________, Has been examined during this pregnancy and may be delivered by a midwife if no complications develop.” And it is signed by a man. Maybe we are continuing this practice in a fancier form through “An Act Promoting Access to Midwifery Care and Out-of-Hospital Birth Options” https://malegislature.gov/Laws/SessionLaws/Acts/2024/Chapter186?

I respectfully submit a request that, at the October 2025 meeting, the Board discuss how informed choice, informed consent and informed refusal is provided for in all aspects of “An Act Promoting Access to Midwifery Care and Out-of-Hospital Birth Options”, especially and including the Rules and Regulations.

Thank you for your consideration.

Sincerely,

Joyce Kimball

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Published: 24 October 2025

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