Public Consultation: Professional Standards Second Consultation

Public Consultation: Professional Standards Second Consultation

This consultation is now closed.

Setting and maintaining high professional standards is fundamental to public protection and public confidence in the midwifery profession. We need to ensure that the College of Midwives of Ontario standards of practice clearly set out the high standards we expect of all midwives.

The development of the new Professional Standards for Midwives (Professional Standards) is a major step forward in reforming our current standards of practice. It forms the first phase of a wider program of work to streamline our approach to regulation to promote targeted and proportionate regulation in the public interest.

Public protection is at the heart of everything we do, and our principles-based approach to the standards is designed to benefit midwifery clients, the greater public, and the profession as a whole.  For more information on our new approach to regulation and what it means in the context of the standards of practice, please read our Consultation Paper.

Our first consultation on the Professional Standards was conducted this past summer.  You can read some of the comments from the first round of consultation here.

During the first consultation, we gathered feedback in three different ways: a survey, comments on the website, and e-mails sent directly to the College. We are grateful for the time and effort given by respondents who replied in detail to our first consultation, and we welcome both the support of, and challenges to, our proposals. The comments have provided us with a wide spectrum of views from midwives, regulatory and midwifery stakeholders as well as clients and the public.  You can read our response to the first round of consultation here.

In our response paper we,

  1. Report on the feedback we received and set out our response to all the issues raised in the first consultation.
  2. Propose changes to the Professional Standards made in response to the feedback received (Appendix A). Please note that where we have made changes to the Professional Standards, additions are shown in purple and deletions have a strikethrough.
  3. Provide a list of standards that will be rescinded with the implementation of the Professional Standards (Appendix B)
  4. Propose an implementation timeline (Appendix C)
  5. Invite further views on the revised Professional Standards by launching the second consultation. It is important that all respondents read our response before submitting their feedback. Please ensure your comments are submitted by 5pm on December 21, 2017. You can leave a comment here on the page, or write an email to cmo@cmo.on.ca either as an individual or together with your practice.

 

Questions & Answers

 Q: What are the Professional Standards that are proposed for midwives?

A:         You can read the proposed Professional Standards here.  We’ve made some changes in response to the feedback received in our first round of consultation, which you can see here. Please note that where we have made changes to the Professional Standards, additions are shown in purple and deletions have a strikethrough.

Q: What’s changing? Will the way that I practise midwifery change?

A: We want to reiterate that the Professional Standards sets out the minimum standards for the midwifery profession in Ontario. There is nothing in the standards that prevents midwives from continuing to work in the model of care as it is defined by the current college standards. For example, midwives can continue to work in groups of no more than four midwives, provide continuity of care in a way that ensures every client knows who will attend their birth and attend every birth with a second midwife. It is up to midwives to define midwifery in Ontario in a way that meets the needs of their clients as well as the minimum standards established by the College. The Professional Standards trusts that midwives know how to do this.

Q: When did this consultation start?

A:  This consultation started on October 19th 2017, and will go to December 21, 2017 at 5pm.  Earlier this summer, we held our first public consultations on the Professional Standards, which occurred over seven weeks in July and August.  You can see the comments from the first round here.    You can also see the timeline for the creation and implementation of the Professional Standards here.

Q: What’s happening next? How will these standards be implemented?

A:  The consultation goes to December 21st, so you can comment anytime between now and then.  We’re also holding a Member Education Day  on November 1st, and we’re inviting members to come and share their thoughts on the day.  If you can’t join us in person, please participate through our webcast.

After the consultation closes, we’ll take time to consider all feedback and incorporate changes in the Professional Standards document where appropriate.  In March 2018, the College Council will approve the final document, and Professional Standards will come into force in June 2018.  You can view our timeline for implementation here.

While our approach to regulation has changed, it won’t necessarily alter the way midwives work today.  Implementing the proposed changes will be relatively easy providing midwives continue to exercise sound professional and clinical judgment, and apply their knowledge and skills in the best ways possible in compliance with the legislation and regulations that govern their practice.

Q: Which standards are being rescinded, and what’s the rationale behind rescinding certain standards?

A:  You can see a list of all the standards that are being rescinded here, along with a brief overview of why they’re being rescinded. 

In our first round of consultation, we heard from some members that they were concerned about specific standards being rescinded.  We’ve addressed these concerns in our response paper, which you can read here.

Q: What did you learn from the first consultation?

A: We reviewed answers to the open-ended questions in both the survey and the website and, in combination with the letters and e-mails, identified some key issues and concerns. From this analysis, the following key themes emerged:

  1. There was strong agreement with our approach to streamlining our standards of practice that would allow midwives to practice more flexibly and in more innovative ways. There was strong support, particularly from other regulators, for our increased focus on the clients and the broader public interest.
  2. There was a broad welcome for the Professional Standards by the profession and members of the public. This was tempered by expressions of concern that midwives might not have the knowledge, skills and judgement to practice competently in the absence of prescriptive rules, that we should have clearer expectations for midwives and that more detail was needed in the Professional Standards.
  3. Some respondents, including the Association of Ontario Midwives (AOM), were firmly opposed to our overall approach to informed choice, continuity of care and choice of birthplace and felt they should remain as individual standards. The AOM, for example, felt that rescinding these model of care standards could result in poorer clinical outcomes because of the potential for medically unnecessary transfers of care and disrupted continuity of care.
  4. Some respondents were opposed to rescinding particular standards (e.g. VBAC and Choice of Birthplace, When a Client Chooses Care Outside Midwifery Standards of Practice) with the implementation of the Professional Standards. They argued midwifery is a marginalized profession and midwives require advocacy tools (in the way of our existing standards).
  5. A few respondents made requests for guidance to help practices understand our expectations and to achieve the right outcomes for clients.

You can read more about the feedback we received, and how we responded to it, in our response paper here.

Q: Has the Professional Standards document changed from the first consultation period?

A:  Yes, we’ve taken all feedback into consideration and changed our Professional Standards document where appropriate.  You can read the updated document here. Where we have made changes to the Professional Standards, additions are shown in purple and deletions have a strikethrough.  We’ve also responded to all feedback we received in our response paper, which you can read here. 

Q: I’d like to share my feedback, but I want to make sure it counts. What are you doing with feedback received in this round of consultation?

A: All feedback is incredibly important to us, and helps us to shape our Professional Standards document.

If you like the general direction of the document but don’t want to leave a long and detailed comment, that’s still helpful. Just comment to let us know you think we’re on the right track, and we can use that feedback too.

You can see how we carefully considered all the feedback we’ve received in the first round of consultations here.

 

Professional Standards: Second Consultation Documents

Response Paper

Appendix A: Professional Standards for Midwives

Appendix B: List of Standards to be Rescinded with the Implementation of the Professional Standards for Midwives

Appendix C: Professional Standards Creation and Implementation Timeline

Appendix D: Formal Feedback

Appendix E: Comparison Between the Professional Standards and the College’s current standards on informed choice, continuity of care and choice of birthplace.

Appendix F: Hierarchy of Documents Governing the Midwifery Profession

 


All Feedback

  1. Midwife

    After careful reflection of the material released by the CMO in this consultation process, we would like to put forward the following. We accept that the new “Professional Standard”, as it is described with its 5 Principles, covers most, if not all, of the specifics held in those standards now proposed to be rescinded. We agree with rescinding the prescriptive clinical guideline-type standards and have the expectation that the AOM clinical practice guidelines and practice protocols will support a high standard of care. As many of us have expressed, our primary concern is losing the “Code of Ethics” and the “Model of Care” standards. They are the long-standing foundational principles of midwifery in Ontario, and embody the reason we believe midwifery is the safest and most respectful form of maternity care for families having babies in Ontario.

    While we understand that the individual tenets described in the “Model of Care” standard are mostly captured within the 5 principles, they are concealed in what appears to be a generic “Professional Standard”. These principles do not have the same optics or cohesive impression when compared to the “Model of Care” standard. In the public interest, it is both necessary and beneficial for clients to see what they can expect from midwifery in the format and presentation of a separate standard describing midwifery as a model of care. We think that representing midwifery as a model of care upheld by the regulatory body is a much a more effective way to enact the College’s new proposed standard which is to “uphold the reputation of the profession… and collectively act in a manner that reflects well on the profession.” (Principle 5) This is also the directive in Principle 4, that states, “Integrity demands that midwives willingly and consistently maintain the reputation and values of the profession.” We believe that the “Model of Care” standard “maintains the reputation and values of the profession” in a way that the new “Professional Standard” does not. The “Model of Care” standard, by its descriptions of continuity of care, philosophy and informed choice, makes it evident that the profession of midwifery is distinctive from other primary care professions in Ontario. The new standard and its principles as they are laid out do not emphasize the fundamental tenets of midwifery in the titles of the principles. The “Model of Care” standard does, and in so doing, upholds the “reputation and values” of the midwifery profession as it stands today.

    The information presented to the public ought to make explicit what is different about midwifery care compared to other health care options in Ontario. We would like to see the standard “The Ontario Midwifery Model of Care” revised and updated, yet remain as a guiding standard. The “Professional Standards and its 5 Principles” would be complementary to the “Model of Care” standard by engaging in more detail, but would not detract from the value of a separately and concisely stated standard.
    By maintaining the “Model of Care” standard, in conjunction with the proposed “Professional Standards and their Principles,” it would be appropriate to rescind the standards of “Code of Ethics,” “Continuity of Care,” “Informed Choice,” “Home and Out-of-Hospital Births” and “Choice of Birth Place.” The information and values contained in those standards is protected and contained within the new proposed standard of 5 Principles and a (modified and updated) “Model of Care” standard.

    The new “Professional Standards and its 5 Principles” may meet the regulatory needs of the College but it doesn’t represent midwifery, nor does it protect midwifery in its essence. It is imperative that the standards published by the College consider how midwifery is received and perceived by the public locally and globally. Given that we are regarded as forerunners in the world because of our respect for professional autonomy, and for providing the best setting for client autonomy, it is essential that the College reflect this in a stronger way than having the details buried in the proposed “Professional Standards” document. By maintaining and updating the “Model of Care Standard” in addition to the newly proposed “Principle Standard,” we strongly believe that the College can achieve just that.

    We believe that one of the most precious aspects of the “Model of Care” standard is in the philosophy section. This section is a statement of the fundamental views and values of midwifery, and it is this philosophy that midwifery consumers are seeking and want protected. It states:
    “Midwives view pregnancy and childbirth as a healthy and normal physiologic process and a profound event in a woman’s [sic] life.”

    “Midwives respect and support their clients so that they may give birth safely, with power and dignity.”

    “Midwives respect the diversity of women’s [sic] needs and the variety of personal and cultural meanings that individuals, families and communities bring to the pregnancy, birth, and early parenting experience.”*

    The College has stated that they cannot regulate a philosophy, however, we feel that this should be a significant aspect of College standards. If a midwife is losing sight of these tenets, or is being bullied by other stakeholders to minimize the importance of these tenets, then having it be mandatory to uphold and represent them can be invaluable. In the current climate where midwives are still not given an equal voice at many negotiating tables, it is instrumental to have such a clear document to refer to and have it supported by the College.

    In summary, we support the “Professional Standards in its 5 Principles” but we ask that the College also collapse the rescinded standards: “Code of Ethics,” “Continuity of Care,” “Home and Out-of-Hospital Births,” and “Choice of Birth Place” into one standard; namely the “Ontario Midwifery Model of Care.”

    Our hope is that the College will consider not rescinding, but revising the “Model of Care” standard.

    We will now continue here to make suggestions for edits and put forward some clarifications needed regarding the new “Professional Standards with its 5 Principles” as they were presented on Nov 1, 2017 at the CMO Educational Day.

    Principle 1: PROFESSIONAL KNOWLEDGE AND PRACTICE
    In the first paragraph we don’t think the word “good” is a measurable or clarifying addition and can be removed.
    8. Change “provide” to “offer” to reflect informed choice language.
    9. Could simply read, “Order tests and prescribe medications as clinically indicated.”

    Principle 2: PERSON-CENTRED CARE
    This is the Informed Choice piece that is so important to many of us and is what many of us believe IS midwifery!
    We think the informed choice principle set out in 20 is well described. We wonder if the words “shared decision making” can have a place here too. Also, if we are not able to keep the “Model of Care” standard can we preserve some of what we quoted above from that document, especially related to context of birth and diversity of peoples.
    25. It says, “Ensure that your personal biases do not adversely affect client care.” We are not sure what this means in practice. Please explain.
    28. We think the phrase “not to the detriment of your clients” obscures the underlying meaning; perhaps it could read, “Manage your practice in a way that prioritizes client-centred care”?

    Principle 3: LEADERSHIP AND COLLABORATION
    This is the continuity of care piece that is so important to many of us and considered by many as essential to the care we provide.
    30. The “ongoing relationship of trust” should require in-person interaction.
    31.1. We suggest to take out the “all” and have it read something like, “Assuming primary responsibility for the care you provide, as a solo primary practitioner or as part of a primary care team of more than one midwife.”
    31.5. This is a very important aspect to clients and we would like to recommend “known to the client” be more explicitly defined. That definition should require in-person meetings and an ongoing relationship to be developed as described in #30.
    34. We agree we should transfer care when the required care exceeds our ability, but what about addressing that midwives should be able to KEEP care when it is reasonable to do so? There are times when the consultant is motioning to assume primary care of the client because they have decided the midwife doesn’t have the knowledge and skill. Is there a place here to say, “only” transfer care when the required care exceeds your knowledge and skills?

    Principle 4: INTEGRITY
    In the opening paragraph here it states, “do what is right.” We would like to suggest instead of “do what is right” it could say, “do and say what is necessary and responsible, both clinically and politically for the purpose of maintaining the reputation and values of the profession.”
    40. The current “Code of Ethics” states, “attempt to provide the best possible care under any circumstance. A midwife may not refuse to attend or abandon a client in active labour.” We suggest maintaining that statement instead of “never abandon a client in labour,” as it’s written in the proposed principle. There is ambiguity around early labour vs. active labour in the principle.
    42. This standards states, “Disclose to the client any harm sustained to them while under your care.” We recognize that this is perhaps an attempt to ensure clients are fully informed of any complications that have arisen during their care, but the phrasing leaves some uncertainties. Perhaps altering the statement to read “known harm” may make this a more attainable directive. We also question if this includes the harm we witness in the hands of another practitioner; for example, the institutionally sanctioned violence that we are sometimes witness to. Is it meant to be physical harm and mental harm? If this is the intended requirement, is it realistic? If we are to disclose harm done by other practitioners, this could be a problem. Many midwives do not have the safe positioning especially in hospitals to be fulfilling this aspect of the standard without jeopardizing their job.
    46. We wonder if it has to say “and not commercial gain”? Could it be edited to state, “Recommend the use of products or services based on evidence and/or clinical judgement.” For example, some practices endorse certain prenatal classes or provide and charge money for prenatal classes and there is a financial gain.
    54. Please explain how the College will evaluate if a practice is managed “in a way that supports the physical and mental well-being of all individuals involved in client care.” Is this related to sleep relief policies? Is this something that should be more directive and explicit?

    Principle 5: COMMITMENT TO SELF-REGULATION
    In the first paragraph, we suggest to strike out the following statement on the grounds of the patronizing tone:
    “ Self-regulation is a privilege that recognizes the maturity of the profession and honours the knowledge and skills possessed by its members. Midwifery was accorded this privilege…”
    Then the first sentence could read, “Self-regulation is based on the premise that midwives will uphold the standards and reputation of the profession, protect and promote the best interests of the client and the public, and collectively act in a manner that reflects well on the profession.”

    Thank you for taking the time to consult with us and giving us the opportunity to be involved in this process. We know the College is not required to take our suggestions and we really appreciate that you are considering them.

    * We would encourage the College to consider inclusive and gender-neutral language in an updated version of the “Model of Care” standard.

    • Are you a: Midwife
    • Organization: Kensington Midwives
    • On behalf of: Organization
  2. Midwife

    I support the guiding idea behind these changes of lessening restrictions on Midwives and allowing for autonomy and ability to evolve with changing proactices and knowedge. I do not understand why this can not still be done within the core framework of continuity of care, informed choice and choice of birthplace. Without these three tenants of midwifery firmly entrenched in the body that regulates and registers us what are we? How are we different? How do clients know what to expect from us where do they go when we don’t uphold these principles.

    Don’t “throw the baby out with the bathwater”! Don’t dilute the importance of continuity of care, informed choice and choice of birthplace.

    • Are you a: Midwife
    • On behalf of: Yourself
  3. Midwife

    As a midwife with more than twenty years of clinical experience, experience as a clinician leader within a large midwifery friendly hospital, work with our professional liability insurer as a member of their board of directors, work within the professional association as a past president and in the Quality Insurance and Risk Management committee, among a number of additional extra-curricular activities related to Quality Improvement and Patient Safety, I hope I am in a position to step back and look at the big picture of what the CMO is hoping to achieve but to also speak to the on the ground experiences of midwives in practice and in communities.

    I laud the CMO’s intentions regarding not over regulating our profession and in supporting the profession to be seen on equal footing with other professions who can be regulated purely from a principles based model. I will say however that I think that it is naive to imagine that the removal of some specific standards which midwives and clients of midwives have relied upon to support the unique and non conforming model of midwifery within the traditional medical system will not have an impact on the quality and safety of care that clients will be able to access. While it was very helpful to see in Appendix E where many of the current standards are still included in the proposed new standards, there has been some detail lost in some of the transition that may make it challenging to provide care to pregnant people in the manner that is integral to midwifery. Even twenty years into its existence, even with patient centred care coming into it’s own in the wider health care system, the model of midwifery which relies on customized, client centred care with informed choice at it’s centre comes up against challenges when faced with community standards within the medical system that may choose a more conservative but not necessarily more evidence based approach. If midwifery is to continue to be able to prove, as it has done, strong clinical outcomes and high levels of client satisfaction, midwifery clients have to be enabled to make those choices and not be inadvertantly limited by the removal of protections from our standards.

    While the professional association can step in and provide resources like Clinical Practice Guidelines to establish best practices for midwives in areas that will no longer be addressed specifically in Standards (i.e. ECVs, Induction/Augmentation, Twin and Breech birth), having the weight of the regulatory body to support practices that clients seek from midwives will provide much more support within the health care system to enable midwives to provide those services. The principled approach presumes that all that is required for a midwife to be able to provide care to her clients as a professional is a self assessment of her knowledge, skills and experience and the expectation that if she is missing KSE she will undertake whatever training is necessary to obtain those so she is competent to provide said services. The problem with this assumption is that a competent midwife, with appropriate knowledge, skills and experience may find herself in the situation of having arbitrary indications for consultation and transfer of care imposed on her practice which would not be prevented by having a professional association clinical practice guideline. I would urge the CMO to reflect on where they may want to continue to provide guidance to those members of the health care system that midwives have to collaborate with in order to provide service to their clients and who may influence the types and levels of service that are made available to clients. If not in the form of standards, perhaps in position statements as with those on VBAC and choice of birthplace.

    As a final thought, I would just like to share that even for myself as an experienced midwife, I have found it challenging to provide feedback to the proposed changes in standards. In providing so much information in your response paper and the accompanying appendices, while the intent may have been one of transparency and comprehensiveness, it actually was an overload of information that made it difficult to respond in a meaningful way.

    I thank the CMO for providing an opportunity for feedback and for working to improve the quality and safety of the care that pregnant people under midwifery care receive and hope that in creating opportunities for new and responsive ways for midwives to provide care that the core tenets of midwifery which we have evidence, result in good outcomes, can still be supported.

    • Are you a: Midwife
    • On behalf of: Yourself
  4. Stakeholder

    Thank you for a second chance to review these Standards. In Alberta, as the CMA moves from the Health Disciplines Act to the Health Professions Act (by the end of 2018), we are constructing our own set of Professional Standards, much the same as yours. You have good rationale for your change, and we are right behind you! We ended up keeping in/adding back the Continuity of Care segment to our draft document, as there is a wish here to keep the key messages within the segment. Our 6 Professional Standards will be going to Alberta Health in January 2018. Thank you for leading the way!

    • Are you a: Stakeholder
    • Organization: College of Midwives of Alberta
    • On behalf of: Organization
  5. Midwife

    While I agree that change is necessary and look forward to any changes that allow more flexibilty and work life balance for midwives, I do have several concerns with the proposed changes.

    My main concern is regarding the 3 tenets of midwifery care. As the CMO stated in the response paper, it is true that the new standards include those tenants (continuity of care, choice of birthplace, informed choice), but they are buried among other generic standards. For example: “30. Provide continuity of care” in found right after “29. Be accountable and responsible for clients in your care and for your professional decisions”, which is very generic and could apply to any profession. The CMO states that the new standards will help the public know what to expect when accessing midwifery care, but in reality, I find that the new standards make it really difficult to identify what differentes midwifery from any other profession. I understand (and agree) when the CMO states that all standards are equally important, but I still feel that the public should be able to quickly understand what makes midwifery unique. I am picturing my initial visit with clients new to midwifery care – how will I explain to them our philosophy? And how will I be able to ensure that, should they move elsewhere and want to have midwives again, those midwives will also follow that same philosophy?

    I also have concerns about some of the standards that were rescinded. If it is the CMO’s role to protect the public, I believe that some of these standards are necessary. For example – postpartum visits. No where else is it stated how often midwives must see clients at home for postpartum visits. With the removal of that standards, clients could be asked to come to the clinic for a day 3 visit – is that really in the best interest of the client? VBAC is another example – yes there are other standards out there (those of the SOGC, the AOM, etc), but clients are still not always offered a home VBAC in certain communities.

    The choice not to include any standards that state that midwives must maintain hospital privileges is interesting – will this make it possible for midwives to provide only home births and transfer care for any hospital births?

    I am also concerned about the rescinding of the standards on complementary and alternative medicine. I want to be certain that I will continue to be able to use things like labour tincture in my practice without having to become an herbalist to do so, and without having to have written documents proving my competency. My competency comes from years of training with and working with midwives who used labour tincture, and hope that practical experience will always be considered sufficient training (as long as I explain to clients to extent and limit of my knowledge, as was required by the old standards).

    Finally, I want to state my concern about the erasure of women from this document. I understand the importance of inclusivity and applaud your efforts, however it does make me sad to see the results. Women are taught from childhood to make themselves small and erase themselves at the benefits of others, and I feel that this is no different. Perhaps the standards could include a sentence such as “midwives provide care to women, their families, and all other childbearing people. The word client is used throughout the text to refer to all those who may receive care from midwives”. Anything to avoid the complete erasure of women!

    • Are you a: Midwife
    • On behalf of: Yourself
  6. Midwife

    I have read through most of the proposed changes and while I think it could be a positive thing, I also see it as an opportunity for midwives to provide sub par care. While we like to think that all practicing midwives are holding themselves to the highest of standards and are providing their clients with unparalleled care, the truth is there are those who are not. The “loosening of the reins” could provide those who don’t hold themselves to high standards to lower their standards even further. I also am concerned about midwives who work in hostile hospital environments and/or work with clients that often choose care that would be seen as unconventional by medical standards. It is much harder to defend oneself with vague standards. While I see the potential for positive change, I am very worried that these changes could be detrimental to those of us who already work in difficult environments.

    • Are you a: Midwife
    • On behalf of: Yourself
    1. Midwife

      These are very good points and I just want to comment that I totally agree with the concerns mentioned above. As the new standards leave more freedom to individual midwives this may also result in big differences in care provided between Midwifery practices or even between midwives in the same practice.

      • Are you a: Midwife
      • On behalf of: Yourself
  7. Midwife

    Upon reviewing the second draft of the proposed Professional Standards, I want to share my support of this draft. These standards will remove prescriptive, ‘micro-managing’ of midwives and rather allow us to work autonomous to our full potential. I believe that these new Professional Standards take into account the evolution of midwifery as a profession and allow new and innovative ways for midwives to work and provide client care based on their specific community needs.

    I cannot state strongly enough that I sincerely and passionately object to the AOM’s statement of lack of support. For whom does the AOM speak? The board? The membership? I don’t recall being asked by them to share my opinion and thus I don’t believe that they, as the provincial association, should be speaking on behalf of their membership without consultation. Yes, they are a stakeholder, but only insomuch as they should be reflective of the membership.

    I also believe that, in reading some of the concerns about removing certain standards, that the proposed Professional Standards continue to capture the tenants of midwifery care, including continuity, choice of birth place and informed choice. Additional prescriptive standards based on each of these principles are, in my opinion, redundant. Why is a VBAC choice of birth place standard needed when the Professional Standard already captures this i.e.. a client has a right to agree or refuse care, no abandonment, choice of birth place.

    I also disagree with the feedback citing concern about the rescinding of the Continuity of Care standard. Guaranteeing every client never meet more than 4 midwives is not attainable 100% of the time in many practices. Additionally, it limits the ability of midwives to find innovative ways to work. Instead, I support a standard of maintaining continuity of care amongst providers, ensuring proper handover etc. as well as continuity of midwifery care in general in the rare times that known midwives are unavailable. This, in my opinion, provides greater protection regarding client safety than maintaining a standard espousing an arbitrary number of midwives (4) must provide care even in extenuating circumstances such as fatigue or illness.

    Lastly, I encourage the College to look more closely at setting standards for the organization of practice groups as that relates to the pervasive problem of MPG “owners” hoarding power and profits. Most of the midwives in this province are not partners, in direct opposition to AOM recommendations, and this has contributed to unhealthy and abusive power dynamics in practice groups across the province. We apparently are self-employed, and yet have little to no protection in our workplaces and little to no professional autonomy due to the funnelling of base case load funds through the practice owner(s) who “own” that budget. The College does have a role to play in this issue, because these power dynamics most certainly affect client safety.

    In short, I support the proposed Professional Standards and feel that these standards will allow the profession to grow and evolve in dynamic, responsive ways into the future. While perhaps necessary at the time of regulation, the current standards are overly prescriptive and are due for critical reflection and adjustment.

    • Are you a: Midwife
    • On behalf of: Yourself
  8. Midwife

    Hello, I agree with the above changes.
    I would like the changes to reflect the desire for midwives to work in alternative models, when ever necessary or needed. Ie. ‘clinic only’ midwives, hospital based midwives, etc. This would accommodate the needs of midwives in various stages of their careers, or who require accommodation based on chronic illness or disability, while reducing attrition within the profession. I don’t believe the proposed changes reflect this, except in rescinding the continuing of care standard.
    I would also like to see more support and ability to work in alternative models, such as independent midwives, midwife/physician groups, etc. This could be promoted by allowing midwives to have their funding attached to the midwife rather than the MPG. I don’t know if the CMO has any ability to address this issue. It could also be beneficial in keeping midwives in their communities, in reducing bullying within the profession, and increasing midwife autonomy.
    I would hope that the addition of well woman care/contraception services and prescriptions and abortion services will also be address.
    I also believe it should be a minimum standard to supply translation services for clients who require it, this is especially important in the current setting of an influx of non-English speaking refugees, non-insured funding availability and to reduce medical errors due to inadequate communication between midwives and clients.
    I believe that is all my feedback

    • Are you a: Midwife
    • Organization: The Hamilton Midwives
    • On behalf of: Yourself
  9. Midwife

    Thank you for all your hard work in reviewing and changing the standards of care for midwives. Overall; it looks good to me and I agree with the changes though I do have to admit that it is somewhat difficult to predict what doors these new standards may open and how they will work out in practice. I do realize that Midwifery is changing and needs to change to allow for more flexibility to accommodate different models of care. I do worry however, that with more flexibility and less detailed standards the vision and philosophy of Midwifery may change as Midwives may possibly start looking into jobs at Ob offices, in hospital jobs etc. I am not necessarily against these changes and am open to change but I worry that our profession will become too medical and that eventually we won’t be any different from other healthcare providers who treat pregnancy and birth as a disease and who’s focus often is on risks and complications. As more and more skills get added to the Midwifery scope of practice I worry that we loose the philosophy that pregnancy and birth are normal natural processes and that as Midwives we are experts in normal childbirth. I really do hope we can maintain the low-risk, experts in normal approach without adding more and more skills to our scope that clearly don’t fit that description.

    • Are you a: Midwife
    • On behalf of: Yourself
    1. Midwife

      I agree, I am concerned about this as well.

      • Are you a: Midwife
      • On behalf of: Yourself
  10. Midwife

    Thank you for accepting feedback from midwives and the public, and posting it for others to read. It helps to understand where others are feeling more work needs to be addressed on the Professional Standards proposed document. I do feel that broadening the standards and eliminating prescriptive documents is beneficial to the growth of our profession. I am curious to see how the model of care may be impacted across the province without a document outlining its definition, particularly in regards to continuity of care. However, as a midwife who has practiced for 5 years, the time that I spent exploring the CMO documents and discussing how they impacted my career was primarily in school through assignments, tutorial and in lectures. There is a certain amount of confidence I have in our profession as a whole that if the MEP continues to teach the philosophy of midwifery to students and this is demonstrated by their preceptors in practice, the new midwives will understand the value of continuity of care without having a prescriptive guideline on the topic.

    • Are you a: Midwife
    • On behalf of: Yourself
  11. Midwife

    I generally agree with the statement

    • Are you a: Midwife
    • Organization: Midwifery Services of Lambton Kent
    • On behalf of: Yourself
  12. Midwife

    The changes seem thorough and thoughtful. I am eager to see how they roll out.

    • Are you a: Midwife
    • Organization: MCPHH-Mississauga
    • On behalf of: Yourself
  13. Midwife

    Looks good to me.

    • Are you a: Midwife
    • Organization: Community Midwives Of Ottawa
    • On behalf of: Yourself
  14. Midwife

    Thank you for all the work on the updates to the standards of practice for midwifery. I really appreciate the effort from the CMO to examine our current policies, standards and guidelines with the intent to be current and evidence based. The speakers on the education day provided some interesting insight into what the purpose of our standards should be and how they can serve to help ensure that midwives are competent.

    The proposed change of standards seems like a huge change to our college, our governing body. When the first round of the changes came out, I have to admit, I did not realize how big the proposed changes were and therefore did not pay a great deal of attention. For this reason, even though the CMO has been working on this for awhile, the timeline for the changes to happen seems short for some of us.

    From speaking with many of my colleagues, although there is a general feeling that the motivation and work of change is good, it is hard to grasp exactly what these changes will mean for how midwives practice and the potential for how they could practice in the future. Although I hear the response from the CMO that midwives can essentially continue to work the way they have been working, if they want, I wonder what the vision for midwifery of the future is and how these changes will precipitate future change in midwifery.

    I also would like to know what future changes to the college should we expect to see after the change to the standards?

    Thank you

    • Are you a: Midwife
    • Organization: Midwives of York Region
    • On behalf of: Yourself
  15. Midwife

    I want to see flexibility on the way midwives work. I am burnout after 30 years of profesional practice.
    I agree that we should follow standards of practice and clinical guidelines of profesional competency. However, I felt that we are being push to do more and more, long hours, and limited time off, neglecting our health, family and personal joy.
    I want to see the opportunity to have flexibility to work with other care providers, work on shift and provide excellent care to clients and to be involve in research without adding more hours to my practice.

    • Are you a: Midwife
    • Organization: On Leave
    • On behalf of: Yourself
    1. Midwife

      Agreed. While the CMO’s mandate is public safety rather than midwife happiness, I do agree that the two go hand in hand. The profession is changing. While we still hold dear the principles of midwifery, we can also agree to allow midwives to work in new and innovative ways that suit both them and their community.

      • Are you a: Midwife
      • On behalf of: Organization
  16. Midwife

    I would like to comment on this second consultation request. I have been an Ontario midwife for a long time and have watched the profession change dramatically. Especially in expanded scope and increased responsibility. The proposed changes are a welcome attempt to align the CMO standards with midwifery today. While growth and change can be challenging to accept and adopt it is imperative that the profession and professional standards adapt to these changes. Midwifery is a regulated health profession and as such it is the responsibility of each midwife to follow the evidence in the provision of care. The comparison of other regulated health care professional governing bodies has demonstrated that the CMO is significantly more restrictive. The scope of midwifery is much too restrictive for the profession in my opinion. Midwives are experts in many important skills that can be utilized in other ways and in other jobs. Midwives need the opportunity to work differently in many different ways in order to remain in the profession. I truly hope that the profession can grow and develop with the times. Protecting the model from so long ago is not allowing the profession to grow!

    • Are you a: Midwife
    • On behalf of: Yourself

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