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Then the yellow flags started.

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Published Date

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.