Gap Analysis of TRICARE Birthing Centers Policy to CABC Accreditation Standards

The purpose of this website is to highlight the areas of TRICARE policy that are supported and enhanced by CABC accreditation standards. By hovering over the TRICARE policy, you will see the specific aligned CABC standard. Since the TRICARE policy is overdue for revision, NACPM completed this gap analysis and offered suggested language changes. NACPM’s analysis of the comparison of the TRICARE policy to the CABC standard is featured to the right of the TRICARE policy. Of course, NACPMs' suggested changes are not the only way to align these two benchmarks. However, if these or similar changes were made, TRICARE contracts would be more straightforward because accreditation would ensure adherence to TRICARE policy.

TRICARE Policy Manual 6010.63-M, April 2021 NACPM Analysis

**AABC Standard 1. “The birth center is a healthcare facility for childbirth where care is provided in the midwifery and wellness model.“**

Although many of the Standards and Attributes evaluated by the Commission for the Accreditation of BIrth Centers are similarly covered by other accrediting bodies, the CABC is the only accrediting body with expertise in the safety and quality of care for freestanding birth centers and alongside midwifery units. It uses the Standards for BIrth Centers as developed and maintained by the American Association of BIrth Centers (AABC).

**Standard 4.A.**
1. Complies with regulations for licensure of birth centers if established for its jurisdiction.
2. Complies with applicable local, state and federal codes, regulations and ordinances for construction, fire prevention, public safety and access for birth centers.
3. Provides an entrance/exit, a waiting area and a bathroom to those who require accommodations for mobility.
4. Maintains a record of routine periodic inspections by health department, fire department, building inspectors and other officials concerned with public safety, as required by the birth center’s local jurisdiction.
5. Provides instruction for all personnel on public safety and conducts at least semiannual emergency evacuation drills.

Although many of the Standards and Attributes evaluated by the Commission for the Accreditation of Birth Centers are similarly covered by other accrediting bodies, the CABC is the only accrediting body with expertise in the safety and quality of care for freestanding birth centers and alongside midwifery units. It uses the Standards for Birth Centers as developed and maintained by the American Association of Birth Centers (AABC).

TRICARE 3.1.3 - 3.1.4.5 These policies list acceptable accrediting organizations (including Commission for the Accreditation of Birth Centers, CABC) and the processes through the Medical Benefits and Reimbursement Section (MB&RS) for recognition. The section content includes information that would be part of the contract dictated by TRICARE, and do not serve a purpose in this analysis.

**Standard 2.c.12** There is adherence to ethical billing practices.

Sections 3.1.4.2 - 3.1.4.3 are proven through accreditation. Financial and organizational record management is viewed as well as evaluations and inspections are conducted during the new and renewal accreditation processes.

Section 3.1.4.4-3.1.4.6. These terms are dictated by TRICARE in the contract with the birth center.

**Standard 4.A.**
Complies with applicable local, state and federal codes, regulations and ordinances for construction, fire prevention, public safety and access for birth centers.
Provides an entrance/exit, a waiting area and a bathroom to those who require accommodations for mobility.
Maintains a record of routine periodic inspections by health department, fire department, building inspectors and other officials concerned with public safety, as required by the birth center’s local jurisdiction.
Provides instruction for all personnel on public safety and conducts at least semiannual emergency evacuation drills.
Prohibits smoking in the birth center.
Guards against environmental factors that may cause injury with particular attention to hazards to children.
Provides adequate heat, ventilation, emergency lighting, waste disposal and water supply.
Provides adequate administrative space for: a) Business operations
b) Secure medical records storage c) Utility and work area
d) Medical supplies storage
e) Staff area
Provides appropriate space to provide the following services for women and families including, but not limited to:
a) Waiting reception area/family room and play area for children b) Physical examination
c) Bath and toilet facilities
d) Birth
e) Emergency care of the woman and/or newborn f) Access by emergency medical service personnel
Maintains adequate housekeeping and infection control.
Provides adequate trash storage and removal.
Provides adequate hand washing facilities for families and personnel.
Provides adequate biomedical waste handling and removal in compliance with local, state and federal regulations.
Has an appropriate disaster plan in place relevant to regional needs.
Has appropriate facility security measures for staff and families.
B. EQUIPMENT AND SUPPLIES
The birth center has readily accessible equipment and supplies, including medications, necessary to:
a) Perform initial and ongoing assessment of the mother and fetus
b) Provide care during birth, including repair of lacerations and management of uterine atony
c) Perform evaluation and, if necessary, resuscitation of the newborn
d) Perform screening and ongoing assessment of the newborn
e) Provide oxygen supplementation for the mother or newborn as needed
f) Establish and provide intravenous access and fluids as needed
There is a system to monitor all equipment, medications, intravenous fluids and supplies.
a) All equipment is appropriately maintained and tested regularly.
b) The inventory of supplies, intravenous fluids, and medications is sufficient to care for the number of women and families registered for care.
c) Supplies such as needles, syringes and prescription pads are appropriately stored to avoid public access.
d) Controlled medications are maintained in double-locked, secured cabinets with a written procedure for accountability.
e) Used hazardous supplies, such as sharps and expired medications, are disposed of properly.
f) Medication management is in compliance with state and federal regulations.
3. The birth center has properly maintained accessory equipment which includes but is not limited to:
a) Conveniently placed telecommunication device
b) Portable lighting including an emergency light source
c) Kitchen equipment usually found in home for light refreshment
d) Laundry equipment usually found in home or contracted laundry services

Environmental Standards for CABC far exceed those of TRICARE policy.

**Standard 2. Planning, Governance and Administration**
The birth center considers the needs of the childbearing community, including regulatory requirements and available resources, in developing services and programs.
The birth center is, or is part of, a legally constituted organization with a governing body that es- tablishes policy, lines of responsibility and accountability. The governing body, either directly or by delegated authority to qualified individuals, is responsible for fiscal management and opera- tion of the birth center.
The birth center is administered by the governing body according to the organization’s mission, goals and policies in an ethical manner that provides a high quality of services while promoting fi- nancial sustainability.
**Attributes required for compliance with Standard**
A. PLANNING
The general geographical area served is defined.
Characteristics of the community served are considered periodically including:
a) Availability of and access to maternal and newborn services including practitioners, hospital obstetrical and newborn services, midwifery services,family-centered maternity care programs, birth rooms/suites, clinics for vulnerable families, laboratory services, supplementary social and welfare services, childbirth education, lactation services and parent support programs
b) The birth center’s impact on the community and the needs of childbearing families for the purpose of program planning and development
c) Changes in the population, environment, regulations, legislation, reimbursement, and their effect on the birth center’s operation
B. GOVERNANCE
The birth center is, or is part of, a legally constituted organization in good standing.
The birth center is governed as an organization with its own governing body, or may be part of a larger healthcare organization, in which the birth center leadership has representation in order to maintain its standard of care and quality of services.
The birth center leadership includes midwives and engages in the following tasks, including but not limited to:
a) Monitors daily operations of the birth center, including relevant aspects of administration, human resources, facility, equipment and supplies, clinical care and health records, and client experience
b) Regularly reviews finances and contributes to budget planning and implementation
c) Regularly reviews clinical guidelines and/or policies and procedures (refer to Standard 7) with clinical staff to assure adherence to current evidence
d) Implements a quality evaluation and improvement program with clear and consistent engagement by all staff (*refer to Standard 7*)
e) Establishes a mechanism for staff and clients to provide input to the leadership
The governing body meets regularly to execute responsibilities for the operation of the birth center and maintains a record demonstrating discussion and decisions. Governing body responsibilities, direct or delegated, include but are not limited to:
a) Formulation of mission and a long-range plan for the birth center
b) Development of organizational structure and/or bylaws which clearly delineate lines of authority and responsibility c) Appointment of a qualified administrator with authority, responsibility and accountability for birth center administration
d) Appointment of a qualified clinical director with authority, responsibility and accountability for clinical services
e) Approval of policies and procedures for the operation of the birth center
f) Approval of a quality improvement program for the operation of the birth center and regular review of quality assurance and utilization data
g) Monitor fiscal, legal and administrative management and accountability “fiscal”
h) Approval of contractual agreements
i) Approval of a conflict of interest policy
C. ADMINISTRATION
There is a plan for the operation of the birth center in the absence of the administrator and/or clinical director.
There are protocols for maintenance of equipment, building and grounds, as well as control of the use of the facility.
The birth center carries general liability insurance.
All written contracts, agreements, policies and procedures are reviewed annually and updated as needed.
There is orderly maintenance and secure storage of official documents of the birth center including network security.
The birth center complies with applicable local, state and federal regulations for protection of client privacy and safety.
Personnel policies and procedures are maintained (*refer to Standard 3*).
Contracts for student education or field experience are approved by the governing body
or its designee.
There are agreements and/or written policies and procedures for collaboration with other agencies, institutions or individuals for services to clients including, but not limited to:
a) Laboratory and diagnostic services
b) Childbirth education/parent education support services
c) Obstetric consultation services
d) Pediatric consultation services
e) Transport services
f) Obstetric/newborn acute care in licensed hospitals
g) Home health care services
Practice guidelines and protocols are provided to the consulting specialists and available to the hospital receiving transfers, upon request.
There is a plan for informing the community of the services of the birth center.
There is adherence to ethical billing practices.
There is evidence of adherence to generally accepted accounting principles and reporting is compliant with state and federal regulations.
There is a plan to ensure fiscal sustainability. “fiscal”
Capital expenditures, as may be required for the continued effective operation of the birth center, are anticipated.
Quality assurance and utilization data are collected, analyzed, reviewed by the governing body and included in planning (*refer to Standard 7*).

The accreditation requirement exceeds TRICARE policy requirements. The CABC Requires extensive planning and implementation of procedural requirements in the following areas; Planning, Governance, Administration, Human resource requirements for quality control and cohesive professional standards, Clinical skills requirements, the maintenance of Health records, Quality evaluation and Improvement, Philosophy of care requirement, and honoring clients rights.

**STANDARD 1.C &D** The birth center is a health care facility for childbirth where care is provided in the midwifery and wellness model. The birth center is freestanding and not a hospital.Birth centers are an integrated part of the health care system and are guided by principles of prevention, sensitivity, safety, cost-effectiveness, and appropriate medical intervention. While the practice of midwifery and the support of physiologic birth and newborn transition may occur in other settings, this is the exclusive model of care in a birth center.
The birth center respects and facilitates a pregnant person’s right to make **informed choices** about their health care and their baby’s health care based on their values and beliefs. The person’s family, as they define it, is welcome to participate in the pregnancy, birth, and the postpartum period. Standard 1.C. SERVICES PROVIDED
1. The birth center provides or demonstrates availability of a mother-centered range of services to meet the physical, emotional, socioeconomic, informational and medical needs of the individual client including, but not limited to:
a) A shared decision-making process for all services related to pregnancy, birth and newborn care
Standard 1.C.a uses the terminology “shared decision-making”.
D. CLIENT RIGHTS
(does not pertain to 3.2.3)
(does not pertain to 3.2.3)
Be informed of the benefits, risks and eligibility requirements for care.
Be informed of the services provided by the birth center and the services provided by contract, consultation and referral.
Be informed of the identity and qualifications of care providers, consultants and related services and institutions.
(does not pertain to 3.2.3)
Participate in decisions relating to the plan for management of her care and all changes in that plan once established including referral or transfer to other practitioners or other levels of care.
(does not pertain to 3.2.3)
Be informed of the birth center’s plan for provision of emergency and non-emergency care in the event of complications with mother or newborn.
Be informed of the client’s rights with regard to participation in research or student education programs. Be informed of the birth center’s plan for hearing grievances.
Be informed of the liability insurance status of practitioners.

CABC requires the utilization of ‘shared decision making’ and informed choice. Expansion of the requirements can be found in a section titled “Client Rights”. The Midwifery Model of Care utilizes a collaborative care structure, where patients/clients, are considered a valuable part of the decision making process. “Shared decision making” is a corner stone to the birth center model of care and core requirement to accreditation.

**Standard 3.2** Professional staff are licensed to practice their profession in the jurisdiction of the birth center, where available.

Beneficiary care. Each woman admitted into an accredited birth center is cared for by or under the direct supervision of professional staff licensed to practice their profession in the jurisdiction of the birth center who is otherwise eligible as an individual professional provider. Majority of birth centers are Midwife led facilities (over 99%). Of those, over 70% are staffed with CPMs working alongside CNMs. Over 50% of the birth centers available are staffed by CPMs alone. If the goal is to increase access to birth centers as a low cost, high value care option then it is imperative to expand coverage to include CPMs.

**Standard 1.C.1.d**) An established consultation, collaboration or referral system to meet the needs of a mother or baby outside the scope of birth center practice in both emergency and non-emergency circumstances

Medical direction. The center has an established consultation, collaboration, or referral system to meet the needs of a mother or baby outside the scope of birth center practice in both emergency and non-emergency circumstances. Given the health care availability and licensing variation across states, accreditation is the best mechanism for ensuring that adequate medical direction for NON routine consultation OR emergency care with an OB GYN and Pediatrician is available for birth center clients.

**Standard 2.C.** There are agreements and/or written policies and procedures for collaboration with other agencies, institutions or individuals for services to clients including, but not limited to:
a) Laboratory and diagnostic services
b) Childbirth education/parent education support services
c) Obstetric consultation services
**d) Pediatric consultation services**
e) Transport services
**f) Obstetric/newborn acute care in licensed hospitals**
g) Home health care services
10. Practice guidelines and protocols are provided to the consulting specialists and available to the hospital receiving transfers, upon request.
Highlighted section d) for pediatric and f) for obstetric/newborn acute care.

Emergency treatment. The center has a written policies and procedures that details at least one backup hospital which will accept and treat any woman or newborn transferred from the center who is in need of emergency obstetrical or neonatal medical care.

Emergency medical transportation. The center has agreements and/or written policies and procedures that details at least one ambulance service which documents that the ambulance service is routinely staffed by qualified personnel who are capable of the management of critical maternal and neonatal patients during transport and which specifies the estimated transport time to each backup hospital with which the center has arranged for emergency treatment.

**Standard 3.1-2 Addresses 3.2.9**
**Attributes required for CABC compliance with Standard**
**Standard 3**
1.    **Professional staff provide evidence of the knowledge, training and skills required to provide the services offered by the birth center, including promoting physiologic birth and breastfeeding.**
**2.    Professional staff are licensed to practice their profession in the jurisdiction of the birth center, where available.**
3.    Professional staff show evidence of malpractice insurance or demonstrate that clients are informed of the absence of coverage.
4.    There are adequate numbers of skilled professional and support staff scheduled to be available to:
a) Meet demands for services routinely provided
b) Provide coverage during periods of high demand or emergency
c) Assure client safety
d) Promote and support physiologic birth
5. At each birth there shall be two staff currently trained in:
a) Adult cardiopulmonary resuscitation equivalent to American Heart Association Class C basic life support
b) Neonatal resuscitation endorsed by American Academy of Pediatrics/American Heart Association
6. Records are maintained for all employed, credentialed or contracted staff, trainees and volunteers participating in birth center care including as applicable:
a) Qualifications
b) Current licensure with independent verification
c) Health screening
d) Malpractice insurance coverage
e) Disclosure of malpractice claims
f) Evidence of peer review and may include letters of reference
g) Evidence of current training in adult cardiopulmonary and neonatal resuscitation
7. The birth center performs annual written performance evaluations for all staff.
8. There are written personnel policies available to all personnel that include but are not limited to:
a) Conditions of employment
b) Respective obligations of employer and employee
c) Benefits
d) Affirmative action
e) Grievance procedures
f) Sexual harassment and workplace violence
g) Non-discrimination
9. The birth center facilitates professional and non-professional staff development including, but not limited to:
a) Orientation of all new staff to the services and programs
b) Access to evidence-based resources
c) In-service education programs to remain current in knowledge and skills
d) Participation in training and continuing professional education programs
e) Involvement in activities of professional organizations
f) Routine, periodic maternal and newborn medical emergency drills
10.          All birth center staff shall have documentation of immunization status for vaccine-preventable diseases in pregnancy.
Birth center personnel shall have training that meets state and federal law including, but not limited to OSHA, Patient Safety, HIPAA and CLIA regulations.

CABCs accreditation process ensures all providers and staff have the knowledge and training required of their position. The standard includes provisions requiring specific additional evidence of knowledge in the areas of physiologic birth (natural birth) and chest/breastfeeding. The standard requires the HR department to maintain records of each team member’s qualifications.

**STANDARD 5**
Health records of the birth center are legible, uniform, complete and accurate. Maternal and newborn information is readily accessible to the client and health care team and maintained in a system that provides for storage, retrieval, privacy and security that is compliant with state and federal standards.
**Attributes required for compliance with Standard**
1. The health record on each client is maintained and includes, but is not limited to, written documentation of:
a) Demographic information and client identification
b) Orientation to birth center care
c) **Evidence of shared decision-making including informed consent**
d) Complete medical history, including family history, sexual orientation, violence and abuse, nutrition, exercise, exposures, and occupational status
e) Initial physical examination, laboratory tests and evaluation of risk status
f) Appropriate consultation and referral of at-risk clients
g) Ongoing prenatal examinations with evaluation of risk factors
h) Instruction and education including: nutritional counseling, changes in pregnancy, self-care in pregnancy, orientation to the medical record system and the understanding of findings of examinations and laboratory tests, preparation for labor, preparation for early discharge, infant feeding and postpartum changes.
i) History, risk assessment, focused physical examination and emotional status on admission to the center
j) Ongoing assessment of maternal and fetal status after admission to care and during the intrapartum period in accordance with evidence-based standards
k) Ongoing assessment of maternal coping during the intrapartum period
l) Labor and birth summary
m) Physical assessment of newborn including Apgar scores, gestational age, feeding, procedures and transition to extrauterine life
n) Ongoing physical assessment of the mother and newborn during the postpartum period
o) Ongoing emotional assessment of the mother during the postpartum period
p) Ongoing assessment of breastfeeding or formula feeding
q) Discharge summary for mother and newborn that includes: follow-up plan for mother and baby, feeding status at discharge, newborn screenings consistent with national standards
r) Ongoing assessment of mother and newborn after discharge until final postpartum evaluation
s) Final postpartum evaluation of mother that includes counseling for family planning, referral for ongoing health issues, and screening for postpartum mental health issues
t) Consultations, referrals and transfers during all phases of care in the birth center
Birth center clients have access to their health information.
The birth center utilizes a transport record documenting information required for transfer to the acute care maternal and newborn hospital service.
There is a system in place for appropriate tracking of maternal and newborn screenings and diagnostic test(s) including documentation of results and follow-up.
There is a mechanism for providing the birth center with a current health record prior to and on admission in labor.
There is a mechanism for providing the health record of the mother and/or newborn to receiving provider and/or facility on referral or transfer to other levels of care.
Health information is protected to ensure confidentiality, retention and availability to practitioners on a 24-hour basis.
Disclosure of protected health information is in compliance with federal and state regulations.

The CABC Standard 5 goes beyond the policy description for medical records listed within TRCIARE. The Standard includes requirements for extensive charting [including informed consent], specifies security of PHI, and accessibility of Patient information with transfer providers.

**STANDARD 7**
The birth center has an effective program to evaluate and improve quality of services for childbearing women and newborns, the environment in which the care is provided, and all aspects of birth center operations.
**Attributes required for compliance with Standard**
A. EVALUATION OF QUALITY CARE
Policies, protocols and clinical practice guidelines are evaluated to ensure that they are consistent with current national standards and best available scientific evidence including, but not limited to:
a) **Ongoing prenatal risk assessment and birth center eligibility**
b) Comprehensive perinatal care consistent with the birth center model
c) Intrapartum care including policies supporting physiologic labor and birth
d) Neonatal care including assessment and resuscitation
e) Postpartum care of mother and infant including feeding practices
f) **Identification of deviations from normal**
g) Management of complications at the birth center when appropriate
h) An established mechanism for transfer to appropriate levels of care when client conditions warrant
The formulary and protocols for medications used at the birth center are consistent with national standards for maternity and neonatal care.
**Chart reviews are performed regularly to review the management of care of individual clients during their course of care and to make recommendations for improving the plan for care.**
Birth center conducts simulation drills to evaluate staff competency and appropriateness of policies and identifies areas for improvement.
There is an effective system for collection and analysis of data which includes, but is not limited to:
a) Standardized review of sentinel events including, but not limited to:
1) Neonatal Apgar <7 at 5 minutes
2) Postpartum hemorrhage of >1000cc
3) Birth weight <2500gm or >4500gm
4) Shoulder dystocia
**5) Emergent transfers of mother or newborn**
**6) Neonatal intensive care unit admissions**
**7) Maternal intensive care unit admissions**
**8) Maternal, fetal or neonatal mortality**
**9) Deviations from written protocols**
**b) Standardized review of all transfers of mothers and neonates to hospital care to evaluate the appropriateness of decision-making and quality of management of the transfer.**
c) Collection and analysis of outcome data compared to national benchmarks including, but not limited to:
1) Antepartum attrition and referral rates
2) Pre-admission and post-admission intrapartum transfer rate
3) Spontaneous vaginal, operative vaginal, and cesarean birth rates including
intrapartum transfers
4) Utilization rates for available methods of intrapartum pain management 5) Episiotomy, third and fourth degree laceration rates
6) Postpartum maternal and neonatal transfer rates
7) Maternal, fetal and neonatal mortality rates
d) Collection and analysis of utilization data including, but not limited to:
1) Orientation sessions
2) Childbirth-related educational programs
3) Time in birth center before and after birth
4) Home visits postpartum
5) Follow-up office visits postpartum
6) Follow-up office visits for newborn
e) Analysis of collected data regarding patient satisfaction with services provided
f) System reviews to identify issues that may impact quality of care including, but not limited to:
1) Health record system
2) Procedures for screening and diagnostic testing
3) Facility, equipment and supplies
4) Human resource programs
5) Billing and accounting practices

Requirement of processes to be in place to review all sentinel events. The Standard is detailed and captures all points of data and quality assurance.

Comparatively, the accreditation process for quality assurance is more extensive than the requirements of the TRCIARE policy.

**This metric is met through multiple standards.**
**Standard 3**. Human Resources
**The birth center has a human resources program** for hiring, credentialing and training staff to successfully support its services.
**Standard 2 B.** GOVERNANCE
The birth center is, or is part of, a legally constituted organization in good standing.
The birth center is governed as an organization with its own governing body, or may be part of a larger healthcare organization, in which the birth center leadership has representation in order to maintain its standard of care and quality of services.
The birth center leadership includes midwives and engages in the following tasks, including but not limited to:
a) Monitors daily operations of the birth center, including relevant aspects of administration, human resources, facility, equipment and supplies, clinical care and health records, and client experience
b) Regularly reviews finances and contributes to budget planning and implementation
c) Regularly reviews clinical guidelines and/or policies and procedures (refer to Standard 7) with clinical staff to assure adherence to current evidence
d) Implements a quality evaluation and improvement program with clear and consistent engagement by all staff (*refer to Standard 7*)
e) Establishes a mechanism for staff and clients to provide input to the leadership
The governing body meets regularly to execute responsibilities for the operation of the birth center and maintains a record demonstrating discussion and decisions. Governing body responsibilities, direct or delegated, include but are not limited to:
a) Formulation of mission and a long-range plan for the birth center
b) Development of organizational structure and/or bylaws which clearly delineate lines of authority and responsibility
c) Appointment of a qualified administrator with authority, responsibility and accountability for birth center administration
d) Appointment of a qualified clinical director with authority, responsibility and accountability for clinical services
e) Approval of policies and procedures for the operation of the birth center
f) Approval of a quality improvement program for the operation of the birth center and regular review of quality assurance and utilization data
g) Monitor fiscal, legal and administrative management and accountability “fiscal”
h) Approval of contractual agreements
i) Approval of a conflict of interest policy
C. ADMINISTRATION
There is a plan for the operation of the birth center in the absence of the administrator and/or clinical director.
There are protocols for maintenance of equipment, building and grounds, as well as control of the use of the facility.
The birth center carries general liability insurance.
All written contracts, agreements, policies and procedures are reviewed annually and updated as needed.
There is orderly maintenance and secure storage of official documents of the birth center including network security.
The birth center complies with applicable local, state and federal regulations for protection of client privacy and safety.
Personnel policies and procedures are maintained (*refer to Standard 3*).
Contracts for student education or field experience are approved by the governing body
or its designee.
There are agreements and/or written policies and procedures for collaboration with other agencies, institutions or individuals for services to clients including, but not limited to:
a) Laboratory and diagnostic services
b) Childbirth education/parent education support services
c) Obstetric consultation services
d) Pediatric consultation services
e) Transport services
f) Obstetric/newborn acute care in licensed hospitals
g) Home health care services
Practice guidelines and protocols are provided to the consulting specialists and available to the hospital receiving transfers, upon request.
There is a plan for informing the community of the services of the birth center.
There is adherence to ethical billing practices.
There is evidence of adherence to generally accepted accounting principles and reporting is compliant with state and federal regulations.
There is a plan to ensure fiscal sustainability. “fiscal”
Capital expenditures, as may be required for the continued effective operation of the birth center, are anticipated.
Quality assurance and utilization data are collected, analyzed, reviewed by the governing body and included in planning (*refer to Standard 7*).

Accreditation requires the formulation of an HR Dept. and the maintaining of staff to handle responsibilities of that department and others. Staff that includes midwives and others complete daily tasks such as: daily operations, administration, patient health records, quality assurance and improvements, clinic care, data collection and reviews. This is not an exhaustive list, but the accreditation process requires many administrative responsibilities and a governing body to delegate that responsibility.

Section 3.3 does not apply to birth centers

Free Standing Ambulatory Surgical Centers requirements do not apply to Birth Centers. Free-standing birth centers do not preform surgical procedures.