The Center for Reproductive Rights Advocates for Comprehensive Criteria in Birthing-Friendly Hospital Designation

The Center for Reproductive Rights (CRR) has submitted a detailed comment to the Centers for Medicare and Medicaid Services (CMS), a division of the U.S. Department of Health and Human Services (HHS), regarding the proposed Inpatient Prospective Payment Systems (IPPS) rule for 2027. This submission specifically addresses a proposed enhancement to the "Birthing-Friendly Hospital Designation," which aims to strengthen the criteria by incorporating additional clinical measures. While the CRR broadly supports the inclusion of these enhanced clinical benchmarks, the organization has emphasized the critical need to integrate considerations of racial disparities and patient experience to imbue the designation with genuine meaning and drive substantial improvements in maternal health outcomes. The comment was officially submitted on June 9, 2026.

Background of the Birthing-Friendly Hospital Designation

The Birthing-Friendly Hospital Designation, first introduced by CMS, represents a significant initiative aimed at improving the quality of care provided to mothers and newborns during the inpatient stay. The designation seeks to identify hospitals that meet certain standards of safety and quality in obstetric care. Initially, the program focused on a limited set of measures. However, recognizing the evolving landscape of maternal health and the persistent challenges, particularly concerning disparities and patient satisfaction, CMS has been exploring ways to refine and strengthen the designation criteria. The proposed rule for 2027 signifies a proactive step by the agency to elevate these standards and encourage hospitals to adopt more comprehensive approaches to maternity care.

The impetus for such a designation stems from alarming statistics regarding maternal mortality and morbidity in the United States. Despite being a high-income nation, the U.S. has a maternal mortality rate that is significantly higher than many other developed countries. This rate has been on an upward trend for decades, with particularly stark disparities affecting Black, Indigenous, and other women of color. Factors contributing to these poor outcomes are multifaceted, including access to quality care, underlying health conditions, socioeconomic determinants of health, and systemic inequities within the healthcare system. The Birthing-Friendly Hospital Designation, therefore, is intended to serve as a catalyst for hospitals to address these issues proactively and demonstrably improve care.

The Center for Reproductive Rights’ Position and Recommendations

The CRR’s comment, submitted as part of the public rulemaking process, acknowledges and supports CMS’s intention to bolster the Birthing-Friendly Hospital Designation by introducing additional clinical measures. These measures are designed to assess critical aspects of obstetric care, such as rates of Cesarean births, postpartum hemorrhage, and neonatal complications. By requiring hospitals to meet higher clinical benchmarks, CMS aims to incentivize the adoption of best practices and ultimately reduce preventable adverse events.

However, the CRR’s submission goes beyond a simple endorsement of the proposed clinical enhancements. The organization argues that a truly meaningful designation, one that genuinely elevates maternal health and addresses systemic injustices, must extend its focus to encompass two crucial dimensions: racial disparities and patient experience.

Addressing Racial Disparities: The CRR highlights that racial and ethnic disparities are a pervasive and deeply troubling aspect of maternal health in the United States. Black women, for instance, are three times more likely to die from pregnancy-related causes than white women, a statistic that underscores the urgent need for the healthcare system to confront its role in perpetuating these inequities. The CRR’s comment stresses that any designation aiming to signify excellence in birthing care must actively measure and address these disparities within participating hospitals. This could involve requiring hospitals to collect and report data disaggregated by race and ethnicity for key maternal health outcomes, and to demonstrate concrete strategies and progress in reducing disparities. Without this focus, the designation risks overlooking the experiences of the most vulnerable patient populations and failing to drive equitable improvements in care.

Enhancing Patient Experience: Beyond clinical outcomes, the CRR emphasizes the paramount importance of patient experience in maternity care. Childbirth is a profound life event, and the way patients are treated, respected, and involved in their care significantly impacts their overall well-being and their perception of the healthcare system. The comment advocates for the inclusion of measures that capture patient satisfaction, perceived quality of communication with providers, respect for patient preferences, and experiences of bias or discrimination during labor and delivery. A designation that prioritizes patient experience would encourage hospitals to foster environments of care that are not only clinically sound but also compassionate, patient-centered, and trauma-informed. This would involve listening to patients, incorporating their feedback, and ensuring that their voices are central to care decisions.

The CRR’s position is rooted in its broader mission to advance the health and rights of women globally. The organization has a long history of advocating for reproductive health services, including comprehensive maternal care, and has consistently highlighted the impact of social determinants of health and systemic discrimination on health outcomes. Their comment on the Birthing-Friendly Hospital Designation reflects a commitment to ensuring that quality improvement initiatives are inclusive, equitable, and truly responsive to the needs of all patients.

The Broader Implications of the Proposed Rule and CRR’s Input

The proposed IPPS rule for 2027, and specifically the proposed changes to the Birthing-Friendly Hospital Designation, carries significant implications for the U.S. healthcare system. If finalized as proposed, the enhanced designation would create a more robust framework for evaluating and recognizing high-quality maternity care. Hospitals that achieve this designation would likely see benefits in terms of reputation, patient trust, and potentially reimbursement or other incentives.

The CRR’s input serves to broaden the scope of what constitutes "quality" in maternity care. By pushing for the inclusion of racial disparities and patient experience, the CRR is advocating for a more holistic and socially conscious approach to hospital quality assessment. This could lead to:

• Increased Accountability: Hospitals would be held accountable not only for clinical proficiency but also for their efforts to achieve health equity and provide respectful, patient-centered care.
• Improved Data Collection and Reporting: The emphasis on disparities would likely spur more granular data collection and reporting, providing a clearer picture of where inequities exist and what interventions are effective.
• Shift in Hospital Culture: The focus on patient experience could encourage hospitals to re-evaluate their internal policies, training programs, and communication strategies to ensure that all patients feel valued and respected.
• Greater Patient Empowerment: By prioritizing patient experience, the designation could empower patients to seek out hospitals that align with their values and expectations for care.

Supporting Data and Context

The urgency for these considerations is underscored by a wealth of data. According to the Centers for Disease Control and Prevention (CDC), in 2021, the U.S. maternal mortality rate was 32.9 deaths per 100,000 live births, a significant increase from previous years. Furthermore, the CDC’s Pregnancy Mortality Surveillance System consistently shows that Black women face disproportionately higher risks, with mortality rates far exceeding those of other racial and ethnic groups. For example, data from 2019 indicated that Black women were 3.5 times more likely to die from pregnancy-related causes compared to white women.

Beyond mortality, maternal morbidity—serious health problems that occur during pregnancy or after childbirth—is also a significant concern. Conditions like severe preeclampsia, hemorrhage, and sepsis can have long-lasting health consequences and disproportionately affect marginalized communities. Patient experience surveys also frequently reveal concerns about communication breakdowns, lack of perceived respect, and feelings of being unheard among diverse patient populations.

The proposed addition of clinical measures by CMS is a necessary step, but it is insufficient on its own. For instance, if a hospital has a low rate of C-sections but still has a significant disparity in outcomes for Black mothers compared to white mothers, simply meeting the C-section benchmark does not signify equitable high-quality care. Similarly, a hospital that achieves excellent clinical outcomes but consistently receives poor patient satisfaction scores, particularly from minority groups, is not providing a fully positive birthing experience.

Potential Responses and Future Directions

While the CRR’s comment has been submitted, it is part of a broader public comment period. Other stakeholders, including healthcare providers, patient advocacy groups, and researchers, are also expected to weigh in on the proposed rule. CMS will review all submitted comments before issuing a final rule.

If CMS incorporates the CRR’s recommendations, or elements thereof, the Birthing-Friendly Hospital Designation could become a more powerful tool for driving systemic change in maternal healthcare. This would require hospitals to actively invest in training their staff on implicit bias, cultural competency, and patient-centered communication. It would also necessitate robust data infrastructure to track disparities and patient experience metrics, and the development of quality improvement initiatives specifically designed to address identified gaps.

The long-term impact of such a comprehensive designation could be a significant reduction in maternal mortality and morbidity, a narrowing of racial disparities in birth outcomes, and a more positive and empowering experience for all individuals giving birth. The CRR’s advocacy underscores a critical truth: achieving true excellence in maternity care demands a commitment to not only clinical best practices but also to equity, respect, and the lived experiences of every patient. The proposed rule offers an opportunity to advance this vision, and the CRR’s comment provides a vital roadmap for making that vision a reality.