Public Comments for 02/22/2022 Unknown Committee/Subcommittee
SB195 - Group health benefit plans; sponsoring associations, formation of benefits consortium, definitions.
The Roanoke Regional Chamber of Commerce strongly supports SB 15 and SB 195. SB 15 will allow businesses the option to offer paid family leave insurance as an employment benefit, and the benefits consortiums created through SB 195 will allow more small businesses offer health insurance to their employees. We thank the committee for its consideration of these bills.
SB219 - Va. Employment Commission; administrative reforms, reporting requirements, electronic submissions.
SB289 - Workers' compensation; anxiety disorder or depressive disorder incurred by law-enforcement, etc.
SB303 - Mortgage brokers; dual compensation.
SB326 - Credit unions; priority of shares.
SB329 - Credit unions; activity authorized for a federally chartered credit union.
SB335 - Health insurance; association health plan for real estate salespersons.
SB344 - Health insurance; coverage for donated human breast milk, effective date.
At Prolacta, we believe in the power of human milk and make a human milk based human milk fortifier used in level 3 and 4 NICUs through-out Virginia and across the country. We also believe that the safety of the human milk given to premature babies is paramount, which is why we support the substitute language requiring any human milk bank operating in Virginia to be licensed by VDH. The use of human milk in the form of donor milk and in the form of fortifier, which are different products that get mixed together to feed NICU babies is on the rise. According to the Human Milk Banking Association of America (HMBANA), their milk banks distributed 9.2 million ounces of donor milk in 2021 – an incredible 22 percent increase over their 2020 distribution. This is fantastic news for babies all over the country, including in Virginia. The CHKD milk bank is part of this expansive effort, doing incredible work into ensuring babies in need receive the donor milk that they need to survive and thrive. But these statistics also show the need for regulation of milk banks that are selling products to our most vulnerable citizens. At present, donor milk is regulated by the FDA as a food, leaving vast gaps in the oversight and regulation of this human tissue. This classification, which was determined before human milk was sold commonly throughout the country, has come under scrutiny by many states in recent years and has resulted in states requiring milk banks to be licensed just like other blood and tissue banks are licensed – by the government and with government oversight. These regulations, while not extensive, are universal and are key to ensuring babies receive safe nutrition, not an unregulated product. Most non-profit milk banks in the United States are dues paying members of and accredited by HMBANA. HMBANA is a great organization doing wonderful work and ensuring that more babies have access to life-saving donor milk. We praise HMBANA for their work. But we believe that, like blood banks, milk banks need to have independent, government regulations and oversight. You will likely hear opposition to the idea that members of HMBANA are required to be licensed, but I want to leave you with a few thoughts on this. First, HMBANA guidelines do have clinical standards, and we believe these should be taken into consideration by VDH as they draft regulations for milk bank licensure. But the HMBANA guidelines also prohibit for profit milk banks and women from being paid for their breast milk, and they simultaneously allow for the sale of raw unpasteurized human milk to their customers. That is why, in statute, there are at least 9 states that require milk banks to receive licenses from the state department of health, and do not allow HMBANA accreditation to serve as an alternative to department of health licensing. And more are following in their footsteps. I want to leave you with one final quote today, from the FDA’s homepage on donor milk and human milk banks. It is, “there are human milk banks that take voluntary steps to screen milk donors, and safely collect, process, handle, test, and store the milk. In a few states, there are required safety standards for such milk banks. FDA has not been involved in establishing these voluntary guidelines.” (emphasis added) I urge you to support the substitute bill to SB 344 to ensure that all milk banks selling into Virginia are licensed by the state. This will ensure babies have the safest milk possible.
SB15 - Private family leave insurance; definition, establishes as a class of insurance.
The Roanoke Regional Chamber of Commerce strongly supports SB 15 and SB 195. SB 15 will allow businesses the option to offer paid family leave insurance as an employment benefit, and the benefits consortiums created through SB 195 will allow more small businesses offer health insurance to their employees. We thank the committee for its consideration of these bills.