The Center for Reproductive Rights has formally submitted a comprehensive comment to the Centers for Medicare and Medicaid Services (CMS) regarding its proposed Inpatient Prospective Payment Systems (IPPS) rule for 2027, specifically focusing on the critical "Birthing-Friendly Hospital Designation." This submission, dated June 9, 2026, expresses strong support for the proposed enhancement of the designation’s criteria by incorporating additional clinical measures. However, the organization also emphasizes the crucial need to integrate considerations of racial disparities and patient experience to imbue the designation with true meaning and to drive tangible improvements in maternal health outcomes across the nation.

Background: The Imperative for Maternal Health Reform

The United States has long grappled with a concerning maternal mortality crisis, a situation that disproportionately affects Black, Indigenous, and other women of color. According to the Centers for Disease Control and Prevention (CDC), the maternal mortality rate in the U.S. remains significantly higher than in other developed nations. In recent years, the rate has hovered around 30 to 40 deaths per 100,000 live births, a stark statistic that underscores the urgent need for systemic interventions. This crisis is not merely a matter of statistics; it represents thousands of preventable tragedies impacting families and communities.

In response to these alarming trends, the CMS introduced the "Birthing-Friendly Hospital Designation" as a voluntary quality initiative aimed at identifying and recognizing hospitals that meet specific criteria for safe and high-quality maternal care. The initial framework sought to establish a benchmark for excellence, encouraging hospitals to adopt best practices and improve their performance in key areas of obstetric care. However, as the initiative has evolved, stakeholders have increasingly called for a more robust and comprehensive approach to ensure its effectiveness in truly safeguarding maternal health.

The Proposed Rule and the Center for Reproductive Rights’ Response

The proposed IPPS rule for 2027, released by CMS, outlines potential adjustments to the payment system for inpatient hospital services. A significant component of this proposed rule is the augmentation of the Birthing-Friendly Hospital Designation criteria. The Center for Reproductive Rights, a leading legal advocacy organization dedicated to advancing reproductive freedom, has meticulously reviewed these proposals. Their submitted comment provides a detailed analysis of the proposed changes, offering constructive feedback and advocating for a more holistic approach.

The Center for Reproductive Rights’ comment specifically applauds the inclusion of additional clinical measures within the proposed designation. These measures are intended to assess a hospital’s performance in critical areas such as reducing C-section rates, improving management of postpartum hemorrhage, addressing preeclampsia, and enhancing neonatal care. By focusing on these quantifiable clinical indicators, the designation aims to drive accountability and encourage hospitals to adopt evidence-based practices that have been proven to reduce adverse events and improve patient safety.

Addressing Racial Disparities: A Critical Call to Action

While acknowledging the value of enhanced clinical metrics, the Center for Reproductive Rights strongly argues that the current framework, even with the proposed additions, risks falling short if it does not explicitly and proactively address the profound racial disparities that plague maternal healthcare in the U.S. The organization points to extensive data demonstrating that Black women are three times more likely to die from pregnancy-related causes than white women. This disparity is not attributable to inherent biological differences but rather to systemic racism, implicit bias, and inequities in access to quality care, socioeconomic factors, and the cumulative impact of discrimination.

The comment submitted by the Center for Reproductive Rights advocates for the inclusion of specific metrics and evaluation criteria that directly assess a hospital’s commitment to and progress in eliminating these racial disparities. This could include:

  • Disaggregated Data Reporting: Requiring hospitals to report maternal health outcomes data disaggregated by race and ethnicity, enabling a clear understanding of where disparities exist within their own patient populations.
  • Implicit Bias Training and Cultural Competency Programs: Mandating or strongly encouraging hospitals to implement comprehensive training for all staff involved in maternal care, focusing on recognizing and mitigating implicit biases and ensuring culturally sensitive care.
  • Community Engagement and Partnership: Evaluating hospitals based on their efforts to partner with community organizations that serve marginalized populations, understanding local needs, and co-developing culturally appropriate care pathways.
  • Equity-Focused Quality Improvement Initiatives: Assessing hospitals’ active participation in and development of quality improvement projects specifically designed to reduce racial disparities in maternal outcomes.

Without these explicit considerations, the Center for Reproductive Rights warns, the Birthing-Friendly Hospital Designation may inadvertently perpetuate existing inequities by rewarding facilities that achieve good average outcomes without adequately addressing the care received by their most vulnerable patient groups.

Elevating Patient Experience: The Human Element of Care

Beyond clinical outcomes and racial equity, the Center for Reproductive Rights also stresses the paramount importance of patient experience in defining a truly "birthing-friendly" environment. Pregnancy and childbirth are profound life events, and the quality of care extends far beyond the purely medical. The organization argues that the designation should also reflect a hospital’s commitment to patient-centered care, respectful communication, and the empowerment of birthing individuals.

To this end, the comment suggests that the designation criteria should incorporate measures related to:

  • Respectful Treatment and Dignity: Assessing whether patients feel respected, heard, and treated with dignity throughout their labor and delivery experience, regardless of their background or circumstances.
  • Informed Consent and Shared Decision-Making: Evaluating the extent to which hospitals facilitate genuine informed consent and actively involve patients in decision-making processes regarding their care.
  • Support for Birth Preferences: Assessing the hospital’s flexibility and support for diverse birth preferences, including options for labor support, pain management, and birth positions.
  • Postpartum Support and Education: Examining the quality of postpartum care, including breastfeeding support, infant care education, and emotional well-being checks, ensuring a smooth transition home.
  • Patient Grievance and Feedback Mechanisms: Evaluating the effectiveness and accessibility of systems for patients to voice concerns and provide feedback, and how hospitals respond to such input.

The Center for Reproductive Rights posits that a hospital can achieve excellent clinical outcomes but still provide a traumatic or disempowering experience for patients. True quality in maternal care, they argue, must encompass both clinical excellence and a deeply humanistic approach that prioritizes the well-being and autonomy of the birthing person.

Implications for Maternal Health Policy and Practice

The Center for Reproductive Rights’ comment carries significant weight in the ongoing discourse surrounding maternal health policy. By advocating for a more comprehensive and equitable framework for the Birthing-Friendly Hospital Designation, the organization is pushing for a paradigm shift in how maternal care quality is measured and recognized.

Potential Impacts of Adopting the Center’s Recommendations:

  • Increased Accountability: Hospitals would be held to a higher standard, incentivizing them to proactively address racial disparities and improve patient experiences, not just clinical metrics.
  • Improved Data Transparency: The emphasis on disaggregated data would shed greater light on existing inequities, driving targeted interventions.
  • Enhanced Patient Trust: A designation that genuinely reflects equitable and respectful care could foster greater trust between marginalized communities and healthcare institutions.
  • Broader Impact on Maternal Mortality: By addressing the root causes of disparities and prioritizing patient well-being, the initiative could contribute to a significant reduction in maternal deaths and severe morbidity.
  • Model for Other Quality Initiatives: The success of this enhanced designation could serve as a model for other quality improvement programs across different areas of healthcare.

Looking Ahead: A Call for Meaningful Change

The Center for Reproductive Rights’ comment on the 2027 IPPS proposed rule represents a crucial intervention in the national effort to improve maternal health. By championing the integration of racial equity and patient experience into the Birthing-Friendly Hospital Designation, the organization is articulating a vision for maternal care that is not only clinically sound but also profoundly just and humane. The coming months will reveal whether CMS will fully embrace these vital recommendations, a decision that will have far-reaching implications for the health and well-being of birthing individuals and families across the United States. The urgency of the maternal health crisis demands nothing less than a comprehensive, equitable, and patient-centered approach.