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On January 7, 2025, Joy Burkhard, CEO of the Policy Center for Maternal Mental Health provided oral comments at the Advisory Committee on Infant and Maternal Mortality (ACIMM) regarding the committee’s draft recommendations to the Secretary of Health and Human Services.

She also submitted her suggestions for improving these recommendations via written comments, which are documented below. 

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Dear ACIMM Committee,

Thank you for providing the opportunity to make oral remarks today, as well as provide written comments about the draft recommendations from the Advisory Committee on Infant and Maternal Mortality (ACIMM) to the Secretary of Health and Human Services.

As noted in the opening paragraph of the draft recommendations, infant mortality is due in part to preterm birth and low birth weight, and the leading contributor to preterm birth is maternal stress (Kornfield, et al). This is one substantive explanation for the higher rates of preterm birth and infant mortality among the Black population. 

Further, maternal mental health conditions are the leading cause of maternal mortality, according to the CDC.  

With this in mind, I am writing to suggest the following additional detail be added to the recommendations: 

Recommendation 1 – Preconception/Interconception Care (PCC/ICC) – Surveillance, Research, and Data 

Comment 1, Measurement – HEDIS

I urge the committee to emphasize the importance of implementing the women’s preventive health and US Preventive Services Task Force and professional association guidelines for screening for maternal anxiety and depression, beginning in pregnancy. This is consistent with the first set of clinical practice guidelines (CPGs) developed for screening, diagnosing and treatment of perinatal mental health disorders, developed by the American College of Obstetricians and Gynecologists.

The ACIMM committee is recommending development of “standardized tools that measure and track” optimal reproductive health. In the decentralized and fragmented U.S. healthcare “system,” the way delivery of care is measured is through HEDIS measures developed by the National Committee for Quality Assurance (NCQA). Payors are required to track these measures and implement quality improvement actions.

A maternal depression screening and follow-up measure already exists, but has not yet been fully implemented nor modified to be inclusive of anxiety.  This committee should modify its recommendations to HHS to request that CMS require the Maternal Depression screening measures be made mandatory for Medicaid plan data collection, reporting and quality improvement in the “Core Set.”  HHS should also be urged to determine ways to require/urge private insurers to do the same. 

Further, the Centers for Medicare and Medicaid Services has the ability to request the development of HEDIS measures.  This committee should request that HHS direct CMS to request NCQA develop HEDIS measures for all recommended interconception/preconception care when such care is recommended by the USPSTF and/or the Women’s Preventive Services Initiative (WPSI). 

Comment 2, Workforce Shortages and Maternity Care Deserts

Please make reference to the additional workforce that can address maternity care workforce shortages, including women’s health nurse practitioners, psychiatric nurse practitioners, and certified peer support specialists (who provide support to women with maternal mental health disorders and substance use disorders).  All 50 states have state-sanctioned peer support training and certification processes. 

Funding to CBOs in shortage areas that hire and provide evidence-based programs delivered through CHW/Doulas/Peers. 

Recommendation 2. Rural Health Systems of Care 

Comment 1: Shortage Areas, not Just Rural Health

Though rural communities should be prioritized, if possible, I highly encourage the committee to change the title of this recommendation to “Maternity Care Shortage Areas, Prioritizing Rural Maternity Deserts” or something to that effect. This is because, as illustrated by HRSA data, there are also hospital closures and shortage areas in urban/suburban areas. Women in all parts of the country, including cities, deserve to have ready access to maternity care and birth centers. 

Comment 2: Maternity Care Payment Reform

I applaud the committee’s focus on recommending bundled maternity care payment models be reconsidered to emphasize appropriate prenatal care.  It is crucial to reimburse for the care we wish providers to deliver. I also urge the committee to make reference to HHS that postpartum reimbursement must also be addressed. Postpartum Medicaid extension is in place in nearly all 50 states, yet hasn’t been implemented because Medicaid agencies haven’t yet addressed reimbursement to obstetric providers for the full 12 months postpartum. Postpartum care is inter-conception care. 

Comment 3: Telehealth -Provider Consultation 

The Federal Maternal Mental Health Task Force released the first national strategy for MMH last year and a corresponding report to Congress. Like the ACIMM draft recommendations, the national MMH strategy includes reference to the importance of telehealth and obstetric provider to psychiatric provider consultation. I strongly agree with the ACIMM recommendation to HHS that Obstetric providers should be able to consult with maternal-fetal medicine doctors for any maternal condition. 

The national MMH strategy emphasizes the need to make the MMH consultation service available to obstetric providers across the country, not just in states that apply for HRSA grants to set up such programs. I believe that the HRSA AIDS/HIV consultation program could serve as a model for providing holistic consultation services nationwide. 

Comment 4: Maternity Care Centers

The MMH Task Force strategy makes the case that the Federal Government has a responsibility to ensure all women have access to obstetric care and labor and delivery units/centers.  Specifically, the strategy notes that the Federal government should create maternity care centers (MCCs) to provide such care. Care could be contracted out to private/non-profit health organizations or be provided/staffed by Federal government employees. Though this will likely require Congressional action, I urge the committee to consider aligning with the national strategy and weaving in the MMC concept into the recommendations to HHS.

Sincerely,

Joy Burkhard, MBA

CEO

Policy Center for Maternal Mental Health

The Congress Continuing Resolution for 2025 funding did not include state Maternal Mortality Review Committees (MMRCs) or continuing funding for the Advisory Committee on Infant Mortality.