Comment Letter on Expanding Access to Paid Parental Leave
By Joy Burkhard, MBA
Our work shaping and reporting on national mental health policy is made possible through a 2023-2024 capacity grant from the Perigee Fund.
In this letter, submitted this week, we urge the Congressional Bipartisan Paid Family Leave Working Group to develop a national paid leave system that supports mothers during pregnancy and postpartum period allowing for time off during pregnancy as needed to attend medical appointments and a minimum of 8 weeks of paid leave in the postpartum period to heal and care for their infants.
We also believe a national paid leave framework should provide fathers with parental leave to support maternal healing and to bond with and care for their infants. Further, we believe other caregivers, whom a mother may name, should be entitled to take paid leave to care for mothers and infants when a father is absent, cannot take paid leave for other reasons, and/or when the mother prefers to be cared for by an appointee. Read more below.
January 31, 2024
Dear Senator Gillibrand, Senator Cassidy, Representative Houlahan and Representative Bice,
First and foremost, The Policy Center for Maternal Mental Health extends deep gratitude to the Congressional Working Group for inviting organizations like ours the opportunity to explore solutions and insights to expand access to paid leave for all Americans.
Our organization’s mission is to close gaps in maternal mental health care, with the vision that all pregnant and postpartum mothers should have ready access to standardized, evidence-based maternal mental health care from providers they respect and trust.
Our letter addresses the following questions found in the request;
“What does research say about the impact of providing paid leave on worker health, job satisfaction, economic mobility, child development, breastfeeding rates and related health outcomes, fertility rate, infant mortality, elderly health, public assistance levels, family income, and recruitment and retention efforts?
What types of leave should a potential federal program cover, at what length, and why? How should different types of leave be prioritized? Should different types of leave be treated differently or does doing so create adverse effects?
What other information would you like us to consider as we attempt to chart a bipartisan path forward?”
In response to these questions, we emphasize the critical impact of paid family and medical leave on maternal and infant health outcomes, including improved maternal health and mental health, and offer a detailed paid leave strategy at the end of this letter.
As our organization is deeply committed to addressing the maternal mental health crisis in the United States, we support the immediate development and implementation of paid leave policies.
When cultivating a paid leave strategy, please consider the following;
Consideration: The U.S. is facing a maternal health crisis. U.S. maternal mortality rates have been on a steady rise over the past several years, with the most recent rate sitting at 32 deaths per 100,000 live births. This is up from 21 deaths per 100,000 in 2020. 1
Consideration: The U.S. is the only OECD country without paid family and medical leave. Additionally, the U.S. has the highest maternal mortality rate of any country in the Organization for Economic Cooperation and Development (OECD), with a rate three times that of other high-income countries. Even more concerning, our country is only 1 of 7 countries without paid family and medical leave.2
Consideration: Maternal mental health concerns are a leading factor in maternal death in the country. A review of CDC data shows that 53 percent of pregnancy-related maternal deaths occur between 7 days and 1 year postpartum, with more than 80% of pregnancy-related deaths being classified as preventable. The leading cause of pregnancy-related death was mental-health conditions. 1 in 8 U.S. women suffer from mental health concerns following the birth of their child.3
Consideration: Paid family and medical leave is a critical tool in influencing maternal mental health outcomes. Those who took paid leave have lower rates of pregnancy-related stress and postpartum depression. Negative psychological effects stemming from return-to-work anxiety can be alleviated when paid leave policies are implemented for postpartum mothers. Studies show that having at least 12 weeks of total maternal leave and at least 8 weeks of paid maternal leave are necessary to combat symptoms of maternal mental health disorders like postpartum depression.4
Consideration: Paid leave can impact utilization rates of prenatal and postpartum care. A recent New York proposal5 provides the first attempt at extending paid leave to prenatal appointments. By offering this extension, health concerns, including maternal mental health, can be addressed prior to birth, increasing the odds of early intervention and prevention methods. Additionally, when more generous policies of up to 12 weeks are considered, there is a proven increase in postpartum visit attendance.6
Consideration: Paid family and medical leave has an impact on the health of infants. Paid leave correlates with a reduction in infant mortality rates. Studies additionally show the linkage between extending leave and a decrease in low birth weight and early-term infants.7 Paid leave provides specific benefits to preterm infants, minimizing maternal-infant separation for those in the NICU,8 which is critical for both maternal and infant health outcomes.
Consideration: There is an uneven distribution of weight of these impacts, with the highest impacted communities including Black women. Where access to paid leave for workers of color is lowest, the maternal and infant mortality rates for black women is significantly higher than their white counterparts, up to 2 times as much in parts of the country. The risk of maternal mental health concerns specifically is 1.6 times higher for Black women.9
Consideration: Comprehensive paid leave maintains strong bipartisan support across the country. Recent polls in several states revealed that 85% of voters, including Democrats, Independents, and Republicans, support the implementation of comprehensive paid leave.10 These results parallel years of bipartisan and nonpartisan national polling showing a robust majority of Americans of all parties support access to paid leave for all through a comprehensive federal paid leave program.11,12
Consideration: The Policy Center encourages the Working Group to consider a paid leave program, similar in structure and with regard to benefits, as the Federal employee leave program.
Proposal:
We urge the working group to develop legislation that supports mothers during pregnancy and postpartum period allowing for time off during pregnancy as needed to attend medical appointments and a minimum of 8 weeks of paid leave in the postpartum period to heal and care for their infants. We also believe a national paid leave framework should provide fathers with parental leave to support maternal healing and to bond and care for their infants. Further, we believe other caregivers, whom a mother may name, should be entitled to take paid leave to care for mothers and infants when a father is absent, cannot take paid leave for other reasons, and/or when the mother prefers to be cared for by an appointee.
As a small employer ourselves, we also ask that the working group consider the benefit to small employers of the social insurance model used in 13 states.
So that employers and families are not required to cobble together confusing and conflicting benefits, we urge the working group to consider a national model that would supplement state benefits to allow a national minimum standard when developing the Interstate Paid Leave Action Network (I-PLAN).
Thank you for your bi-partisan consideration of women’s and families’ needs as well as employers’ needs. We urge you to continue to work across the aisle to support a robust paid leave benefit that supports mothers and families and their ability to thrive and contribute as working members of society.
Thank you for the opportunity to comment on this important issue.
Sincerely,
Joy Burkhard, MBA
