To provide an example of the content of administrative petitions, here are excerpts from an administrative petition filed in the state of New York “For Rules and Regulations Declaring Prenatal Care a Public Health Service to Be Provided by the State and for Standards Establishing Access to Such Service By Low-Income Women”:

On the cover and in the first few pages, the petition identified:

Petitioners: Redistribute America Movement/Downtown Welfare Advocates Center, a membership organization of poor people—98 percent women with children—working for change in society; and individual petitioners Ebie Brown, Saratoga Springs, New York; and Karen Thomas, Brooklyn, New York.

Respondents: Commissioner, New York State Department of Health; Head of Maternal & Child Health, New York State Department of Health; Commissioner, New York State Department of Social Services.

Petition Prepared By: Community Action for Legal Services.

Endorsements By Elected Officials: Over 20 members of the New York City Council, three State Assemblymembers, and a Congressman, all individually listed.

Organizational Endorsements: Over 75 organizations—health organizations, medical and nursing schools, organizations serving children and families, civil rights, religious, and women’s organizations—individually listed with a brief description of each organization and its constituency.

Individual Endorsements: Several individual endorsements.

The Table of Contents included:

Statement of Purpose 1
Introduction 2
Infant Mortality, Low Birth Weight, and Inadequate Prenatal Care 3
Chart I: Infant Mortality Rates of Selected Health Districts 5
Chart II: Low Birth Weight Infants/Selected Health Districts 7
Charts III & IV: Late or No Prenatal Care 10, 11
Prenatal Care Makes a Difference 12
Cost-Effectiveness of Prenatal Care 15
Current Availability of Services 17
Financial Barriers to Access 19
Operating Policies of Clinical Facilities 23
Lack of Public Awareness 23
Inadequate Attempts to Improve Prenatal Care 24
Statutory Basis for Petition 26
Petitioning Process 27
Proposals 28
Appendix A: NYC Infant Mortality 32
Appendix B: NYC Low-Birth-Weight-Infants 33
Appendix C: Upstate Neonatal Deaths by Birth Weight 34
Appendix D: Prenatal Care 35
Appendix E: Patients Not Registered for Prenatal Care 36
Notes 37-39

Excerpts of text from each section:

Introduction
… .Despite a slight overall decrease in the infant mortality rate statewide, the quality of care available to a pregnant woman in New York State and the likelihood of positive birth outcome still depend largely on where she lives, her economic status, and her race. A review of health districts in New York City alone shows a significantly higher infant mortality rate in poorer health districts than in more affluent areas. For example, the infant mortality rates in the Morrisania and Mott Haven health districts in the Bronx were 21.4 per 1,000 births and 18.2per 1,000 births respectively as compared with a rate of 12.1 per 1,000 in the Fordham, and 11.6 per 1,000 in the Westchester health districts

Infant Mortality, Low Birth Weight, and Inadequate Prenatal Care: A Statewide Crisis
During the past two decades there has been a dramatic decline in the infant mortality statewide, from 24.1per1,000 live births to 12.5 per 1,000 live births (Vital Statistics of New York State). Yet there still exists marked interregional and interracial disparity in infant mortality. Although the disparity is greatest in New York City, areas of poor infant health can be found in many New York counties. Poor and minority women have a higher rate of infant mortality, statewide. The infant mortality rate among nonwhite women was 60 percent greater than among white women. A comparison of selected New York City Health Districts illustrates striking differences in the infant mortality rates between poor neighborhoods and the city’s more affluent areas (See Chart I and Appendix A). . . .

Prenatal Care Makes a Difference
Recent clinical studies in New York and elsewhere demonstrate that high quality prenatal care, combined with aggressive community outreach, improved pregnancy outcome. A comprehensive approach was taken by one South Carolina health district with excellent results. Other community-based prenatal care services show similar results. Denver, Colorado, has an integrated and comprehensive system of city run health care clinics. Similarly, Loundes County, Alabama, experienced a 50 percent decrease in infant mortality after the opening of a new neighborhood health center. In California, La Clinica de la Raza instituted an aggressive community outreach program stressing.

The Cost Effectiveness of Prenatal Care
At the current hospital clinic Medicaid reimbursement rate of $65 per visit, in New York City the cost of prenatal care for each mother at an average of nine visits is only $590. The average DAILY cost of a neonatal intensive care unit is $1,000 to $1,5000. The average hospitalization is 20 days. Finally, individual health clinics prove to be cost-effective when their operating expenses are compared to state savings.

Current Availability of Services
Before we can address the numerous conditions that hinder access to prenatal care, we must first look at the actual number of facilities physically available to pregnant women. Lack of an adequate number of facilities affects both urban and rural areas.

Financial Barriers to Access
Inability to pay, compounded by strict Medicaid eligibility requirements and restrictive clinic practices, is one of the most important causes of lack of prenatal care. A recent study in Los Angeles County illustrates this problem. Financial policies toward non-Medicaid eligible women. . . .

Operating Policies of Clinic Facilities
Even if a pregnant woman can overcome the many financial barriers to receiving prenatal care, she must often face discouraging bureaucratic obstacles once she is accepted. A recent report by the office of the president of the City Council on the Health and Hospitals Corporation, by far the largest provider of outpatient care citywide, revealed that.

Lack of Public Awareness
Any approach to improving access to prenatal care statewide must not only resolve the financial and bureaucratic barriers that exist but also must answer the educational needs of pregnant women as well. They must be made aware not only of the availability and location of services but also of the need to seek early care.

Inadequate Attempts to Improve Prenatal Care
In the report to the New York Legislature on the Maternal and Child Health Services block grant, the state Health Department stated that “In order to improve the health of our population, we must improve the health of our newborns and children.” The department also reported that the most intensive efforts will be geared toward improving the poor health and high infant mortality rate among the high risk population. Yet despite this verbal commitment, financial constraints have frustrated the department’s efforts:
• Funding to the Medical and Health Research Association of New York City, which operates the nine Maternal and Infant Care Centers in targeted high-risk areas has been cut 21 percent
• Less than one-half of all eligible women are currently participating in WIC
• The Improved Pregnancy Outcome program, a statewide effort to stress the importance of prenatal care through community education, will receive no maternal and child health funds after

Statutory Basis for the Petition
New York Public Health Law grants the state Department of Health the authority to “promote or provide diagnostic and therapeutic services for maternal and child health and other conditions and diseases affecting the public health.” (New York Public Health Law § 201(h)). The state Department of Health also has the authority to appropriate state aid to both counties and cities for the purposes of improving public health services. (New York Public Health Law §605, §606). Yet despite the fact that both the legislature and the state Department of Health have recognized a public need

Petitioning Process
The state Department of Health Administrative Policies and Procedures Manual Item No. 71 addresses the department’s rule-making process.

Proposals
1. The state Department of Health should adopt regulations which recognize and regularize the classification of prenatal care as a public health service. This can be done through

2. The establishment of prenatal care as a public health service should include clear standards providing for financial accessibility by low-income women, regardless of Medicaid eligibility or residents status. Prepayment should be eliminated

3. The regulations should also include standards for providing adequate notice to pregnant women of financial policies. Pregnant women should be informed clearly at the time.

4. To ensure accessibility by low-income women, the regulations should also establish standards for implementing a community outreach program. The program should be geared toward

In addition to the adoption of the above regulations, the petitioners also request that the state Department of Health and the state Department of Social Services adopt the following proposals to implement the proposed regulations.

1. Increased state funding for the Emergency Nutritional Assistance Program. Last year, the state supplemented the Federal WIC program by allocating.

2. The institution of an aggressive media outreach program to inform the public of the need and availability of prenatal services.

3. Take the administrative steps necessary to ensure that Medicaid benefits to all eligible women be continued and maintained through the prenatal and postnatal period regardless of a change in the woman’s financial status. This would.

4. Provide additional community-based prenatal clinics in high-risk areas. This would

5. Increase the number of available health-care personnel through increased reimbursement of private practitioners. Public utilization of private physicians and midwives could be