Vermont regulators back certification for community doulas, cite Medicaid coverage and potential cost savings

The Office of Professional Regulation told the Senate Health committee on Wednesday that it supports S 53, a bill to establish certification for community-based doulas in Vermont and to enable Medicaid coverage for certified doulas.

Jennifer Cohen, general counsel for the Office of Professional Regulation, told the committee that “OPR fully supports this bill” and that the office favors certification — a credential that requires proof of qualifications but is not a mandatory license for everyone who practices as a doula.

The testimony framed the proposal as a targeted regulatory approach intended to improve birth outcomes among marginalized communities while avoiding overregulation. Cohen and Lauren Hibbert, Deputy Secretary of State, said the Sunrise review conducted by OPR found evidence that doula support can reduce use of epidurals, cesarean deliveries and postpartum depression — outcomes that can lower both human and fiscal costs to Medicaid and the health system.

Cohen told lawmakers that national and state data informed OPR’s recommendation: the U.S. maternal mortality rate in 2021 was 32.2 deaths per 100,000 live births, and Medicaid recipients are “80 percent more likely than privately insured folks to have severe maternal morbidity.” She said that in Vermont 38 percent of births are covered by Medicaid and that “between 2021 and 2023, there were eight perinatal maternal deaths in Vermont, and all of those individuals were folks receiving Medicaid.”

Committee members and several witnesses raised concerns about how the proposal would interact with federal Medicaid reimbursement rules. A stakeholder identified in the hearing transcript as Diva had earlier told the committee that voluntary certification might not meet minimum federal requirements for Medicaid reimbursement; Cohen said that concern had not been raised during OPR’s Sunrise process and that OPR would follow up to understand the issue.

Cohen described certification as the right-sized regulatory tool for community-based doulas — a subset of the profession defined in the testimony as doulas who provide culturally congruent, peer-based support to birthing persons in under-resourced communities. She said rulemaking after passage would define competencies and acknowledge prior experience so that long-practicing community doulas are not excluded.

On implementation logistics, OPR estimated an initial cost of about $25,000 to build the profession’s infrastructure — IT, stakeholder outreach, rulemaking and staff time — and said the office would begin rulemaking immediately if S 53 passes so it can meet an anticipated implementation date of July 1, 2026. Committee member Alan asked about reimbursement rates; Cohen and others said that the Medicaid agency and its staff (Alex McCracken was cited) have already developed a rate methodology and that those documents could be posted for the committee.

Lawmakers also pressed OPR on training and accreditation. Cohen acknowledged national doula certification programs exist but said many are expensive and may not address the cultural competency required for Vermont’s community-based model; she said a Vermont-based certifying approach is likely and that existing local practitioners and new organizations could contribute to competency standards.

No formal vote or committee action occurred during the session. Cohen and Hibbert offered to provide written follow-up material to answer outstanding technical questions, and committee staff agreed to post the Sunrise report and the cited rate methodology for members to review.

The discussion highlighted the balance lawmakers must weigh between expanding access to perinatal support through Medicaid and ensuring any certification and reimbursement approach meets federal requirements and supports a sustainable, culturally competent workforce.