In a recent meeting of the Joint Committee on Agency Rule Review, Marie McCausland, chair of the Doula Advisory Group for the Ohio Board of Nursing, raised significant concerns regarding proposed rule 4723-24, which she argues could have detrimental effects on doulas and birthing individuals in Ohio. McCausland, a certified postpartum doula and lactation consultant, emphasized the urgent need to expand the doula workforce in the state, particularly given that over 67,000 births were covered by Medicaid in 2020, representing approximately 53% of all births.

She highlighted that the current rules, as written, could lead to a loss of life and increased healthcare costs, as many agency-certified doulas may leave Ohio to avoid penalties for misrepresenting their credentials. McCausland pointed out that the language in the legislation appears to conflate agency-certified doulas with state-certified doulas, potentially criminalizing the use of the title \"certified doula\" for many practitioners.

During her testimony, she referenced the support of various legislators who had previously backed bills aimed at improving doula services, urging them to reconsider the implications of the current rule. McCausland also noted that the Board of Nursing has not provided clear guidance on how agency-certified doulas should identify themselves post-implementation of the rules.

Additionally, she expressed concerns about the disciplinary actions outlined in the proposed rules, particularly regarding the potential for racial bias in enforcement, given the lack of diversity on the Board of Nursing. McCausland called for the removal of the disciplinary section from the rules until more inclusive measures could be established, emphasizing the need for culturally competent care to address disparities in maternal and infant mortality rates.

In conclusion, McCausland urged the committee to amend the language defining \"certified doula\" to clarify the distinction between state and agency certifications and to reconsider the disciplinary measures that could disproportionately affect marginalized communities. Her testimony underscores the critical role doulas play in maternal health and the need for supportive policies that recognize their contributions.