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To the Ohio Department of Health:
As a nonprofit think tank focused on solutions to health, social, and economic issues throughout Ohio, The Center for Community Solutions (Community Solutions) welcomes this opportunity to comment on the Ohio Department of Health’s (ODH) proposed rules about hospital licensing. Community Solutions contributes nonpartisan research, policy analysis, communications, and advocacy to improve the wellbeing of Ohioans. Over the past several years, Community Solutions has been committed to examine and offer policy solutions concerning infant and maternal health in our state. We acknowledge that data within this realm will contribute to strategies to reduce infant and maternal deaths in Ohio. Hence, we support the improvement of maternal health in the state and will be providing suggestions on Chapter/Rule 3701-22-12 about annual reporting.
Suggestions for hospitals to provide frequent reporting on maternal deaths and maternal morbidity.
We appreciate the efforts of the Ohio Pregnancy-Associated Mortality Review (PAMR) to continue to report statistics about pregnancy-related deaths and offer interventions on how to address them. The latest report from PAMR shows that there were 211 pregnancy-associated deaths between 2017-2018 and 72 of them were pregnancy-related. Even though this report was released in 2023, the data is six to seven years old which is outdated. Therefore, we suggest that hospitals provide annual reporting on pregnancy-associated and pregnancy-related deaths. By doing so, advocacy experts and other stakeholders across the state can help birthing people in their pregnancy and postpartum journeys as soon as possible.
In addition, we appreciate PAMR for providing information about maternal morbidity in Ohio. Unfortunately, Ohio has seen little progress in alleviating severe maternal morbidity (SMM) as the rate remains stable. Racial disparities remain prevalent as illustrated by the fact that the SMM rate among Black women was almost two times higher (112.2 per 10,000 deliveries) than white women (60.5 per 10,000 deliveries). Though, that data is also outdated by five years. We request that hospitals seeking licenses under the state provide annual data about maternal morbidity, disaggregated by race. Reporting frequent data will help address maternal morbidity at both community and organizational levels throughout the state.
Thank you for the opportunity to provide public comment about hospital licensing. If you have any questions or concerns about these topics, please contact us.
Sincerely,
Tara Britton
Director of Public Policy and Advocacy
Edward D. and Dorothy E. Lynde Fellow
tbritton@communitysolutions.com
Brandy Davis
Fellow, Medicaid Policy
bdavis@communitysolutions.com
Natasha Takyi-Micah
Public Policy and External Affairs Associate
ntmicah@communitysolutions.com
Sources:
Ohio Department of Health. (2023). A report on pregnancy-related deaths in Ohio 2017-2018. Ohio Department of Health. https://odh.ohio.gov/wps/wcm/connect/gov/960f9320-f4bc-4752-b6cb-990be663a31a/A+Report+on+Pregnancy-Related+Deaths+in+Ohio+2017-2018.pdf?MOD=AJPERES&CONVERT_TO=url&CACHEID=ROOTWORKSPACE.Z18_M1HGGIK0N0JO00QO9DDDDM3000-960f9320-f4bc-4752-b6cb-990be663a31a-oG4C2Up
Ohio Department of Health. (2020). Severe maternal morbidity and racial disparities in Ohio, 2016-2019. Ohio Department of Health. https://odh.ohio.gov/wps/wcm/conect/gov/0657b23a-baba-4a74-b31c-25e216728849/PAMR+SMM+Final.pdf?MOD=AJPERES&CONVERT_TO=url&CACHEID=ROOTWORKSPACE.Z18_M1HGGIK0N0JO00QO9DDDDM3000-0657b23a-baba-4a74-b31c-25e216728849-nIngvoH
