Report 2023-110 Recommendations

To improve the average time it takes for fetal death registration statewide, the Legislature should amend state law to require hospitals, or any medical facilities where fetal deaths may occur, to initiate the creation of the fetal death certificate for any fetal deaths that occur at their facilities. In doing so, the Legislature should reaffirm that physicians, or hospital staff as their delegates, are responsible for entering the required medical information into the fetal death certificates and should clarify that physicians must sign the certificates before transferring responsibility for the next steps of certificate completion to funeral homes.

To ensure the effective enforcement of fetal death registration timeliness requirements, the Legislature should amend state law to require CDPH to regularly notify the Medical Board, the Funeral Bureau, and any other relevant licensing entity, such as the Osteopathic Medical Board, of instances in which registration data indicate that physicians or funeral establishments are repeatedly failing to comply with these requirements. The notification should include the information necessary for the licensing entity to adequately investigate delinquent fetal death registrations.

To reduce the time that parties involved in the fetal death registration process take to notify one another that a certificate is pending action, CDPH should, by June 2024, submit a request to its registration system vendor to develop and implement in the system an electronic notification mechanism that will alert the appropriate user outside the system, such as by email, that a certificate is awaiting that user's action.

To better fulfill its duty to oversee the fetal death registration process, CDPH should, by June 2024, begin to hold meetings regularly with local registrars to identify and resolve issues related to fetal death registration. CDPH should include in such meetings representatives for parties involved in the registration process—such as hospitals, physicians, and funeral homes—as well as representatives from relevant licensing entities—such as the Medical Board and the Funeral Bureau—to obtain additional perspectives about ongoing causes for delays.

To better ensure the effectiveness of its help desk, CDPH should, beginning in June 2024, periodically survey local registrars to solicit feedback on their experience with the help desk and should use this feedback to improve help desk processes as necessary.

To mitigate registration delays and ensure that all hospitals and funeral homes with a responsibility to complete their portions of fetal death certificates are able to rapidly fulfill their obligations, CDPH should, by June 2024, notify hospitals and funeral homes that lack access to its registration system for fetal deaths of their legal obligations in the fetal death registration process and provide instructions on how to access the data system used to fulfill those obligations.