Response to Public Comments

Response to Public Comments
Expressions of Interest in the Improving Maternal Health by Reducing Low-Risk Cesarean
Delivery Affinity Group
CMS-10398 #76, OMB 0938-1148
CMS received two public comments on CMS-10398 #76 (Expressions of interest in the
Improving Maternal Health by Reducing Low-Risk Cesarean Delivery Affinity Group). Both
comments were from private individuals. One comment was in support of this expression of
interest form and affinity group to improve maternal and infant health outcomes. The other
comment was concerned about the expression of interest form requirement was burdensome and
the fact that the affinity group meetings are not public.
Comment 1: I support the policy for expressions of interest in improving maternal health by
reducing low risk cesarean delivery for a few reasons. First reason being that maternal health
determines a child’s health. According to the CDC, maternal and child health is “vital to creating
a healthy world” (CDC Global Health Maternal and Child Health, 2014). When maternal and
child health is affected generational health disparities are created. A second reason being that
cesarean deliveries take a toll on the mothers healing process. It is vital for a mother to feel like
she can return to her daily activities or get into a routine to take care of their new infant. The
third reason I would support efforts in reducing cesarean deliveries would be that it takes a toll
on the mother’s mental health. Compared to vaginal deliveries, women who have cesarean
deliveries are 6 times more likely to develop postnatal depression 3 months after delivery
(Boyce, P. M., & Todd, A. L., 1992). Cesarean deliveries pose a short-term and long-term health
risks to mothers and their children, and all efforts should be taken to reduce low risk cesarean
deliveries.
CMS Response: Thank you for your comment in support of our work to improve maternal
health by reducing low-risk cesarean delivery.
CMS Action: None.
Comment 2: Although vaginal delivery is the preferred method of delivery for both mother and
infant health, this continues an unnecessary burden on state and local entities. Often times, health
care providers and administrators of these programs are continuously bombarded with paperwork
requirements that are unfunded and without thought to the time that is taken away from actual care of
patients. There are also serious concerns about transparency and open government when
subcommittees are allowed to meet privately (closed to the public). The risk to the general public
outweighs the stated concerns. Portions of meetings that concern personal information may be
conducted privately, however, all other meetings should be conducted openly.
CMS Response: Thank you for your comment. This expression of interest form is a one time
request and it is voluntary. It only needs to be completed by state Medicaid and CHIP agencies
that wish to participate in the Affinity Group. The Affinity Group provides no-cost technical
assistance for states who would like guidance in developing and implementing a quality
improvement project to improve maternal health through lowering the rate of low-risk cesarean
deliveries. The Affinity Group is not a subcommittee; it involves 1:1 coaching with a quality
improvement advisory team as well as some group workshops and peer to peer learning.
CMS Action: None