I’ve served as a traditional, or “lay,” midwife since 2018.
Before that, I spent five years as a hospital advocate and unassisted-birth doula, apprenticing under two midwives who taught me a model of care that predates licenses, boards, and billing codes.
In Pennsylvania, that model is technically illegal.
And yet, the same state that threatens us with prosecution also equips us to serve.
The Legal Contradiction
Pennsylvania criminalizes unlicensed midwifery under the Midwife Regulation Law of 1929 (Act 155) and “practicing medicine without a license” under the Medical Practice Act of 1985 (63 P.S. § 422.10).
But there’s a catch: there is no license pathway for direct-entry, CPM-credentialed, or traditional midwives.
If you’re not a nurse-midwife under a physician’s supervision, you can’t even apply for the license you’re accused of lacking.
You’re invisible on paper but indispensable in practice.
The State Says “Stop.”
The Health Department Says “Here’s Your Equipment.”
Pennsylvania’s own agencies both recognize and rely on traditional midwives:
NPI Numbers:
Federal law allows midwives to hold a National Provider Identifier (NPI) without a state license. With an NPI, we can submit vital records, order labs, and function inside national health databases.Birth Certificates:
The Department of Health (DOH) gives us credentials to file out-of-hospital birth certificates through its official registry system.Newborn Screening Kits:
The DOH issues us the same heel-prick screening kits used in hospitals and trains us to collect and submit them.Lab Orders:
LabCorp accepts requisitions from any provider with an NPI — including traditional midwives.
Yet the State Board of Medicine calls those same orders “evidence of practicing medicine without a license.”
So the Department of Health trains us, the state laboratory depends on our data, and LabCorp honors our credentials—while the prosecutorial arm of that same government labels those actions criminal.
That isn’t oversight. It’s institutional schizophrenia.
What Actually Triggers an Investigation
Pennsylvania doesn’t have a defined “scope of practice” for traditional midwives, so each district attorney decides for themselves where the line lies.
Complaints don’t require harm — only disapproval.
Here’s what routinely gets midwives flagged or investigated:
Writing or interpreting lab results
Ordering or interpreting ultrasounds
Performing or repairing perineal sutures
Continuing care beyond 42 weeks
Supporting breech or VBAC births at home
Offering nutritional or herbal support for mild issues (UTI, blood-pressure fluctuations, etc.)
Using words that sound “medical” in public materials (“diagnose,” “treat,” “patient,” “prescribe”)
Transfers after a long labor — even when mother and baby are stable
Accepting clients the hospital labeled “not candidates for home birth,” including:
Babies with known Trisomy 13/18/21 or other anomalies whose families have consulted with specialists to confirm genetic or structural diagnosis that appears compatible with stability at birth.
Benign congenital conditions (like small VSDs, cleft lip/palate, clubfoot) where the hospital insists on mandatory NICU protocols but parents opt for normal physiologic delivery at home
Post-dates pregnancies or families refusing induction against hospital advice
Simply serving families who have been threatened or dismissed by a medical system now looking for someone to blame
You don’t need a loss, an injury, or a scandal.
You just need to have helped the wrong family—the one who said “no” to the hospital.
My First Investigation
My first formal complaint came from a hospital attorney.
I know that because the investigator—another Philly native—let it slip during one of our early meetings.
That attorney gathered three of my client charts and filed them with the state.
Each case was managed properly. Each was documented, transferred, or completed safely.
A planned home birth that resulted in stillbirth
When we arrived, we could not confirm fetal heart tones. We immediately called for transfer.
At the hospital, a C-section confirmed that the baby had already passed from a cord accident prior to our arrival.
I remained with the family throughout the surgery, postpartum recovery, and the bereavement care that followed.A planned breech birth
The baby developed non-reassuring heart tones during active labor. We transferred promptly, and the hospital birth was uncomplicated and healthy.A postpartum transfer
The mother sustained a third-degree tear, and her newborn’s respiratory rate was slightly above normal. We transferred baby in with mother out of caution.
That was enough for a hospital attorney to frame as “evidence” of illegal practice.
Their administrator had already said aloud that they “don’t support traditional midwives.”
And that’s all it takes.
The Investigation Process
My office was inspected without me present.
They photographed supplies, read every chart, and scrutinized my equipment.
According to the DA, the following actions could qualify as “practicing medicine”:
Writing or interpreting lab requisitions
Performing sutures
Interpreting ultrasound findings
Managing post-dates pregnancies with testing protocols (like a biophysical profile)
Sound familiar? It’s identical to what was cited in the Diane Goslin case (Goslin v. State Board of Medicine, 1830 C.D. 2007, Pa. Commw. Ct. 2008*).
In that case, Goslin was found guilty of “practicing midwifery without a license” simply for doing routine prenatal checks, collecting labs, and attending births.
After months of questioning, the state concluded that my work did not meet the threshold for “practicing medicine.”
But that was luck.
Plenty of midwives never get that grace.
The Bigger Question
If the Department of Health trains us, equips us, issues our NPI numbers, and relies on our data for newborn screening—
how can the same state claim we’re practicing illegally?
The answer isn’t about safety.
It’s about control.
The moment birth becomes independent, someone in power feels threatened.
How to Protect Yourself When the Law Makes You a Target
This next section outlines exactly how to build legal insulation in a hostile state:
Contract clauses that define your lawful scope
Disclosure and consent language that documents client choice
How to use your NPI, LabCorp privileges, and newborn-screening authority without incriminating yourself
How to chart and escalate safely when serving “outlier” families
What specific documentation patterns prosecutors look for—and how to flip them to your advantage
