On June 19, 2019, Assembly Bill A364B and Senate Bill S3344B were passed in New York State. Following the passage of these bills, New York will require all doulas to be professionally certified under state guidelines—only those certified may provide doula services.
While these bills were created with the intention of expanding doula care and access to marginalized communities, the proposed legislation contradicts these efforts. Ancient Song Doula Services believes that the state certification process and legislation, as it currently stands, will negatively affect community-based doula organizations of color and communities of color disproportionately.
Join us and support Ancient Song Doula Services as we demand our concerns to be addressed by politicians and the needs of our communities and families be fully met within this legislation.
Our concerns are as follows:
We want to make sure that non-certified doulas can still provide services in New York State if this bill becomes law. It seems that the bill draws a distinction between “certified doula services” and regular doula services, which is good. However, there are a couple of places, noted below, where this could be made more clear.
The bill states that “only a person certified under this section shall be authorized to use the title ‘certified doula.’” The term “certified doula” has been in place for a long time and is used by many different certifying organizations. We don’t believe New York State can lay claim to it and suggest that they use the term “NYS-certified doula” or “New York State certified doula.”
An examination requirement administered by the state is redundant and a potential barrier for community-based doulas. Proof of certification from a credible organization is evidence of a high level of training and preparation for doula work. Instead of an examination requirement, we believe that the focus should be on requiring skills-building for community-based doula work, including in birth/health equity, racism/implicit bias, case management.
The bill states that a requirement for state certification includes being of “good moral character as determined by the department.” We would like to know how “good moral character” will be determined? Is this standard for Medicaid providers? The unknown parameters of this assessment can create a barrier to community-based doula care and support.
New York State will require a fee of $40 to the department for application consideration and certification, which can provide a barrier for community-based doulas. We also need clarity on which doulas would be exempt from taking this examination.
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