June 19, 2019
The Honorable Andrew M. Cuomo
Governor of New York State NYS
Capitol Building Albany, NY 12224
Dear Governor Cuomo,
Traditional Doula and Midwifery Arts (TDMA) is an international doula certification organization based out of Long Island New York, founded in 2015. This past year we published our first book titled, Traditional Doula and Midwifery Arts, where we highlight over 100 doulas we have instructed and certified as doulas. Many of them are doing amazing work in the birth community. On June 15th, 2019, we were made aware of assembly bill A364 (senate bill S3344). On June 18th, this bill passed in both houses. This bill is detrimental to TDMA doulas, their families, and the families they serve. At this time, we respectfully request your veto of the above referenced bill.
Firstly, this bill calls for title ownership of “certified doula” by the State of New York. This is problematic because this title has been in use since 1992. It was first used by DONA International in 1992 and has since become a universal title used by doulas both nationally and internationally. We have many New York doulas who have had this title extended to them by their certifying bodies, including TDMA.
Another deeply concerning aspect of this bill is there are no provisions to protect working doulas who choose not to become “certified doulas” under the new statute. Typically in New York, if a person does not hold permission from the office of professions and their respective boards, they are then considered to be operating outside of the law. This bill paves the way to make doula work punishable by law.
It is stated that “This act shall take effect on the ninetieth day after it shall have become a law.” Since doulas typically are hired months in advance of a birth, where will this leave the birthing people who have set up doula care agreements? Many pregnant people will be abandoned due to this bill as doulas often begin working with families during the prenatal period.
We are also greatly concerned that this bill did not have input from the doula community at large and especially those organizations who are working hard to close the gap in racial disparities. We believe that the voices of black and brown led doula organizations should be centered and should be invited to the conversation around expanding access. The most overlooked birthing population are indigenous birthing people. New York does not even keep statistics on indigenous birth. Indigenous statistics are lumped into the category titled “other” or are folded into hispanic or black categories because they don’t come from federally recognized tribes or don’t have a tribal enrollment number. TDMA is 50% indigenous owned. Dr. T’Karima Ticitl is the cofounder and co-director of TDMA. She has been a birth and postpartum doula since 2011 and is a now a recent midwifery graduate from SUNY downstate. She was certified through DONA International and TDMA. She has dedicated the past eight years of her life to doula work. She is very involved with her indigenous communities here in New York and has great concern for how this bill will affect them.
The new requirements pose as additional barriers for doulas who come from and work within New York’s most vulnerable communities. We have evidence that when birthing people are served by members from within their own communities, we have greater positive outcomes.
The additional requirements including the fee, exam and additional education will become barriers and reduce access to culturally concordant doula care that is so desperately needed at this time.
New York is in a maternity care crisis and has been for some time. We have unacceptably high rates of mortality and morbidity, disproportionally so for black and brown birthing people. Black birthing people are 12 more times likely to die in childbirth than white birthing people. Many counties have higher than the national average C-section rates, and we have high rates of postnatal mood disorders. Currently, nine counties in the state of New York have no obstetricians, six have no midwives, and two have no midwives or obstetricians. Standardizing and regulating doulas in this manner will only serve to reduce access to independent doula care at a very inopportune time.
Again we respectfully ask you to veto this bill and re-introduce a properly thought out and advised version in the next session.
T’Karima Ticitl, PhD, CD, midwifery graduate, co-founder and co-director
Mary Betsellie, CD, IPSP, co-founder and co-director TDMA