HB 7214, An Act Concerning Maternal Health

TESTIMONY OF THE CONNECTICUT HOSPITAL ASSOCIATION
SUBMITTED TO THE PUBLIC HEALTH COMMITTEE

Monday, March 17, 2025

The Connecticut Hospital Association (CHA) appreciates this opportunity to submit testimony concerning HB 7214, An Act Concerning Maternal Health. CHA:

      • Supports the establishment of the perinatal mental health task force and asks the committee to add hospital representatives to the task force established in Section 1
      • Supports the hospital doula-friendly policies advisory committee established in Section 3
      • Opposes the maternity care report card in Section 2, as there are several existing sources of data and information available to the state on maternity care

Connecticut hospitals and health systems care for patients, strengthen the state’s economy, and support vulnerable communities across the state. Every day, they work to improve healthcare access, affordability, and health equity. Even as they face ongoing challenges, hospitals provide world-class care to everyone who walks through their doors, regardless of their ability to pay. Hospitals also support an exemplary workforce as the largest collective employer in the state, contribute significantly to the state’s economy, and invest in their communities addressing social drivers of health.

HB 7214 seeks to improve maternal healthcare in Connecticut through the establishment of a perinatal mental health task force to enhance mental healthcare received by mothers in the state and create an advisory committee to study hospital policies regarding doulas with the goal of increasing hospital policies that are deemed doula-friendly. Additionally, HB 7214 proposes the creation of a maternity care report card whereby hospitals and birth centers would report quantitative and qualitative metrics related to maternity care to the Department of Public Health (DPH).

Perinatal Mental Health Task Force

Section 1 calls for the creation of a perinatal mental health task force and outlines proposed membership of the task force. CHA asks the committee to add hospital representatives to the task force, as CHA leads Connecticut birthing hospitals in the implementation of the national Alliance for Innovation in Maternal Health (AIM) patient safety bundles to improve maternal care. A core component of AIM is a focus on perinatal mental health conditions. Additionally, CHA notes that the specificity of the inclusion of only an international board certified lactation consultant (IBCLC) on the task force excludes participation of other lactation professionals who are similarly qualified.

Maternity Care Report Card

Section 2 requires the Commissioner of Public Health to establish an annual maternity care report card for birth centers and hospitals that will evaluate maternity care provided at such birth centers and hospitals. While hospitals are focused on all aspects of patient experience and value the voices of patients as central to quality and safe maternal care, we have significant concerns pertaining to data availability and health privacy that fundamentally impact the feasibility and utility of the maternity care report card proposed in Section 2.

1. Data availability and validity:
Equity “score” or equity “grade”: To our knowledge, there is currently no national consensus statement, recommendation, or established guideline providing a definition of “equity score” or “equity grade” for hospitals in maternity care. Any proposal to create an equity score or grade that has not been validated, deemed to be psychometrically reliable, or repeatedly tested across geographies, patient acuity levels, and hospital characteristics, creates the potential to arbitrarily rank or grade hospitals. Arbitrary rankings would do little to influence equity in maternal care. In fact, the creation of a grade or score that is not well-established, tested, and trusted could potentially exacerbate inequities.

Patient income: The bill would require a report card to include, but need not be limited to, quantitative metrics, qualitative measures based on patient-reported experiences and an equity score and grade for each birth center and hospital disaggregated by race, ethnicity, and income level. To report data on patient income would require each patient seeking care at a hospital to disclose their income level prior to or during the receipt of care; income is something that many patients may not feel comfortable disclosing and could potentially discourage individuals from seeking needed care at hospitals. Currently, hospitals do not systematically collect data on the income level of patients. Requiring hospitals to report patient-level income data would create a substantial burden on hospitals and patients.

Qualitative data: It is unclear how qualitative data, for example patient stories and comments, would be utilized in a quantitative or empirically based report card. Qualitative data can be coded into broad themes or topics, but this requires deep expertise from qualitative researchers and the use and understanding of coding software for qualitative data. The majority of hospitals neither employ qualitative researchers nor possess qualitative coding software. To categorize and code qualitative data to be transformed into metrics utilized in a report card would require large expense in software and staffing for hospitals, and the creation of an entirely new data system that does not currently exist.

2. Data privacy issues:
Reporting indicators such as maternal deaths, or even severe cases of maternal morbidity, could violate important privacy rights. For example, in Connecticut, we have, on average, 5-6 maternal deaths a year. Even Connecticut’s current Maternal Mortality Review Committee (MMRC) convened by DPH does not allow information on hospital or birth facility to be reported due to privacy concerns that mothers may be easily identified given the relatively small numbers. Furthermore, current DPH Adverse Events Reports only list maternal health indicators by facility type (acute care hospital vs. fertility/childbirth centers) and not by hospital/facility name to avoid similar privacy concerns.

3. Acknowledgement of current maternal health models of care and statewide efforts to improve maternal health:
The proposed report card suggests a dichotomous (yes/no) or categorical (grades of A, B, C, D) view of maternal care. Yet current medical, public health, and scientific models of maternal health equity fundamentally acknowledge the role and intersectionality of the social, environmental, political, and economic influences on maternal health and birth outcomes before, during, and after pregnancy and not just during labor and delivery.1,2,3 These social drivers of maternal health include the social and healthcare experiences of a mother prior to pregnancy, during pregnancy, and in the 12-month postpartum period. A report card narrowly focused on the birth event would overlook the other large and important drivers of maternal health equity in our state, such as food and housing security, receipt and access to prenatal care, discrimination, and substance use and mental health conditions prior to and during pregnancy.

Several statewide maternal health initiatives, including two specifically led by the Department of Public Health, should be considered as data sources for any maternal health equity initiative. The Pregnancy Risk Assessment Monitoring System (PRAMS) and the Reproductive Justice Alliance both collect data on patient experience of maternal care from surveys and focus groups that can be examined at the county and regional level. These data contain important insights on respectful maternal care as experienced by patients during pregnancy, at delivery, and throughout the postnatal period.

Section 2 also requires the commissioner to establish an advisory committee to conduct a critical analysis of the report card’s data and develop and issue recommendations to birth centers and hospitals to improve maternal health outcomes. It is unclear how this advisory committee would be distinct from current DPH maternal health advisory groups that issue recommendations, such as the Maternal Mortality Review Committee or the Maternal Health Task Force convened as part of the newly awarded maternal innovation grant from the Health Resources and Services Administration (HRSA) to DPH.

Hospital Doula-Friendly Policies

Section 3 of the bill proposes the creation of an advisory committee to conduct a study and develop recommendations for making hospitals more doula-friendly. CHA is currently working to promote and foster collaboration in the provider-doula relationship before, during, and after labor and delivery events in hospital settings. Through a partnership with the Fairfield County Community Foundation’s Black Maternal Health Initiative, CHA is building a community of practice and creating a doula-provider facilitated grand rounds training. As such, CHA is pleased to see the advisory committee proposed in Section 3 will include representation from hospitals.

Although CHA supports efforts to advance equity in maternal health and healthcare, as reflected in the implementation of a four-part strategy to advance maternal health4, a report card, such as the one proposed in Section 2, has substantial flaws due to data availability, data integrity, the current science and statewide efforts on maternal health, and patient privacy, and should be rejected in favor of working with existing statewide maternal health initiatives to leverage data already available to design solutions.

Thank you for your consideration of our position. For additional information, contact CHA Government Relations at (203) 294-7301.

1Office of the Surgeon General (OSG). The Surgeon General’s Call to Action to Improve Maternal Health [Internet]. Washington (DC): US Department of Health and Human Services; 2020 Dec. 4, Strategies and actions: Improving maternal health and reducing maternal mortality and morbidity. Available from: https://www.ncbi.nlm.nih.gov/books/NBK568218/
2 Simmons, D., Gupta, Y., Hernandez, T. L., Levitt, N., van Poppel, M., Yang, X., & Nielsen, K. K. (2024). Call to action for a life course approach. The Lancet, 404(10448), 193-214.
3 Grobman, W. A., Entringer, S., Headen, I., Janevic, T., Kahn, R. S., Simhan, H., & Society for Maternal-Fetal Medicine. (2024). Social determinants of health and obstetric outcomes: a report and recommendations of the workshop of the Society for Maternal-Fetal Medicine. American journal of obstetrics and gynecology, 230(2), B2-B16.
4 https://cthosp.org/issue/maternal-health/