Don’t allow access to breastfeeding support to be limited! Please act today!

The Affordable Care Act requires lactation support to be reimbursed as a women’s preventive health service.  HealthConnect One joins with other national organizations who agree with reimbursement for lactation services, but oppose the creation of a Medicaid reimbursement code that would limit reimbursement to International Board Certified Lactation Consultants (IBCLCs).

We support the call by Healthy Children’s Center for Breastfeeding to oppose a CMS code that would limit reimbursement to IBCLCs.  

We believe that breastfeeding peer counselors, community-based doulas and other perinatal community health workers should be included as approved breastfeeding support providers.  The Affordable Care Act authorizes the use of Community Health Workers in Section 5313, and promotes their use in health reform. CMS needs to stay consistent with the overall vision of health reform, with an expanded health care team that includes community health workers.

Here is the statement posted by Healthy Children on their Facebook page earlier this week:

URGENT!!!!!!!!!!!

In January, the USLCA submitted an application to the Centers for Medicare and Medicaid Services (CMS) for a new Health Care Common Procedure Coding System (HCPCS) code to describe lactation consultant services performed by IBCLCs. While Healthy Children supports the concept of creating a code for lactation consultant services, we oppose a code that would limit reimbursement to IBCLCs.

The CMS issued a preliminary decision in which it declined to create a HCPCS code for lactation services. This decision is up for reconsideration at a meeting scheduled for May 29, 2013. The USCLA plans to make a presentation and is soliciting the submission of comments on its proposal. We have prepared a proposed comment for you to submit as a Certified Lactation Counselor, Advanced Nurse Lactation Consultant, or Advanced Lactation Consultant. Please take a moment to help ensure fair, open access to lactation care for all mothers and babies.

To share your views with CMS, Healthy Children’s Center for Breastfeeding proposes the following comments, which you can adapt as you see fit:


To be considered by CMS, your comments should be submitted via email to HCPCS@cms.hhs.gov 
by May 15, 2013.

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Unintentionally Disenfranchised?
Sahira Long and Kim Bugg offer some perspective on this topic here on Momsrising.

10 Comments

  • http://www.momsrising.org/blog/unintentionally-disenfranchised/

    Effort such as this will further disenfranchise under served moms, babies and families. It’s all about this capitalistic society. As soon as money is involved in an endeavor, there will be bullies poised to want it all!

    • Thank you, Kimarie – this was a GREAT piece, and really helped put some perspective on this for us. ~ RoiAnn (at HC One)

      • Anonymous

        NO! There is a HUGE difference in a CLC (certified lactation counselor) and an IBCLC (International Board Certified Lactation Consultant). CLCs should not be receiving reimbursement for consultations. There is a lengthy process to become a board certified lactation consultant and to become a CLC, only requires 5 days attending a workshop.

  • MamaB

    “HealthConnect One joins with other national organizations who agree with reimbursement for lactation services, but oppose the creation of a Medicaid reimbursement code that would limit reimbursement to International Board Certified Lactation Consultants (IBCLCs).”

    There are existing codes for things like lactation education. Doctors are already billing for their services. There is no existing code for services provided by an IBCLC. That is why the request was made by USLCA on behalf of USA IBCLCs. Because physicians would be able to bill for services rendered by an IBCLC, more women would have access to the full range of breastfeeding care.

    “We believe that breastfeeding peer counselors, community-based doulas and other perinatal community health workers should be included as approved breastfeeding support providers. ”

    All of these resources are wonderful. I’m a peer counselor and I love it! 🙂 I have a real appreciation for the work HealthConnectOne is doing and hope other communities eventually start their own programs. To be clear, only IBCLCs are qualified to provide clinical breastfeeding services. Peer counselors, postpartum doulas, CLCs, CLEs, etc. do not have the education or experience necessary to provide clinical breastfeeding support. Yes, they all are very important parts of the maternal health team. Yes, they are able to help breastfeeding mothers and babies with basic breastfeeding management issues and as such, are a vital part of their communities. That doesn’t mean that their services warrant a code for reimbursement under Medicaid.

    Imagine the slippery slope this would create. The women who need the help most that would suffer the most. Rather than everyone trying to fight for the same “right” to provide care and get paid, we should be fighting to assure that ALL women have access to the same level of care. In the end, this is about what will help mothers and babies most. We should leave our egos out of it.

  • Anon 2

    While I think there is a place for non-IBCLC breastfeeding counselors (I’m a group counselor myself), I strongly agree with anon.

  • In the last couple of years the Healthy Children Center for Breastfeeding has perpetuating a lot of misinformation about IBCLCs that is simply not true. This particular piece is perpetuating a verifiably incorrect statement that about coding. There are existing codes for health care practitioners as well as lactation education and those won’t disappear. So despite the misinformation, peer counselors will not be the least bit impeded by codes for IBCLCs. Neither will MDs, nor RNs. All have codes.

    The Healthy Children Center for Breastfeeding has also perpetuated the myth that the IBLCE exam doesn’t test competency. The CLC exam which is a written test at the end of five days of course work and some role plays tests short term retention. The IBLCE exam is taken after much more extensive course work as well as months to years of supervised practice. Thus, the IBLCE exam tests retention of applied, not just theoretical knowledge. In New York State the least amount of time any licensed health care practitioner has to undergo supervised practice is 300 hours for an audiologist. That is more than the entire 5 day course to become a CLC or even the 10 day course to become an ALC. The IBCLE pathway requirements for supervised practice are well above those of audiologist.

    Mothers deserve to have support from family, friends, their health care practitioners, the community, peer counselors and many other helpers. IBCLCs fully support and encourage that. What the Healthy Children Center for Breastfeeding has been doing is putting out misinformation that besmirch the reputation of those who spend the extra effort to learn about the clinical management of breastfeeding in depth and spend the extra effort to undergo supervised practice so that they develop the in depth experience to provide comprehensive care for complicated situations.

    It is a sad day when an organization puts profits for their short term courses over collaborating with those who provide more in depth care. There is no need to try to destroy IBCLCs in order to make a profit. And it is scandalous to start a petition under false pretenses.

  • CalliopeWoman

    Very well said, Mama B. I am so disturbed by the animosity that this issues seems to stir up. Breastfeeding education is an absolutely important thing. Theoretically, if women are well-educated about breastfeeding before their babies arrive, they will be able to avoid many of the common problems women encounter today. Many women really need not only education, but they need to communicate with more experienced nursing women. They need to be reminded that they and their babies are normal in this society that still wants to make them feel abnormal.This is not the primary job of an IBCLC. An IBCLC is most helpful in problem solving and providing specific options for moms to consider when they are having issues with breastfeeding. An IBCLC’s job is to help these women in crisis, or when there are special circumstances. An IBCLC is also supposed to refer to the appropriate HCP if necessary. That might be the mom’s OB, the Ped., or an ENT, for instance. It might also be the local support group or LLL. It might also be to refer to a local CLC for some general support and education after the baby is born, and after the crisis has passed. There should be referring going on left and right. It’s not like there are not enough moms and babies to go around. There is a place for all of us. The reason we need a code for the IBCLC for Medicaid is so that public health recipients have access to the same standard of care as the stay at home mom who lives in some wealthy suburb. Currently, there is no way for public health to regain the money they need when employing and paying IBCLCs for that purpose. I cannot emphasize enough that having an IBCLC-exclusive code will make sure that a mom in crisis does not waste valuable time working with someone who does not have the expertise an IBCLC has.– while she thinks she is getting the expert care, to boot. Time is crucial in many cases and most women don’t have the time and energy — and sometimes the self-confidence to look for better help, much less the money. We are all in this together folks. Let’s not let slings and arrows divert us from the real issues here. Peace. This is a women’s issue. Period. Remember Dr. Benjamin’s Call to Action on Breastfeeding?

  • Helen

    I agree wth Kimarie. A PC or CLC could be and is, just as effective. We have been serving the underserved, making home visits, cheering and encouraging new moms before anybody said there was money in it. Pcs and CLCs also know their scopes of practice. I have many dear friends who are IBCLCs. We value what each brings to the mom. We need to work together because ultimately, we have the same goal. Or do we?

    • MamaB

      Helen, I have been both a volunteer and a paid PC. You won’t find very many other people that are a bigger proponent of mom to mom support than me and that’s not an overstatement. I firmly believe there is nothing else like mom to mom support. Anytime a mom needs cheering or encouraging, a PC is the best one for the job!

      You are correct. PCs are trained to know their scope of practice, practice only within it, and yield to professionals when a problem is beyond their scope. I think we would agree that PCs are integral to providing the necessary support “on the ground”, especially in under served communities. I believe we need a lot more PCs in order to provide support to the most women possible. We definitely need more community organizations to start and maintain peer counseling programs.

      When you say that a PC or CLC could be “just as effective”, I am not sure if I agree or disagree. I would finish that statement with “when a mother needs information or encouragement”. That, of course, includes things like assessing latch, giving tips for overcoming common breastfeeding issues, etc. When a mother needs clinical breastfeeding support, she needs an IBCLC. There are situations when a CLC/PC/CLE/PP Doula/CLS/etc could be “just as effective” as an IBCLC, but there are also situations when they would not.

      All women deserve access to care appropriate to their needs. If they need to see an IBCLC, they shouldn’t be limited to seeing a CLC or PC. These are not equal qualifications. Women in under served communities deserve access to IBCLCs, too. How many people would agree that the government should reimburse the care provided by a patient care tech or Certified Nursing Assistant because there aren’t enough Nurse Practitioners to be available to everyone? The roles of these are all very important to patient care, but they are different. They can do many of the same things up to a point, but one doesn’t replace the other. How is the issue we are discussing any different? Everyone deserves access to the level of care they need.

      This shouldn’t be about money or egos. No one has ever got rich off providing breastfeeding support, and surely no one will get rich by being reimbursed by Medicaid (currently a pittance even for physicians). We are talking about providing breastfeeding families with care appropriate to their needs. The point of seeking a billing code for clinical care provided by an IBCLC is so that MORE women can get the help they need, not less! Codes already exist for breastfeeding education. It is already possible for physicians offices to bill for these services. It is not possible for them to bill for services rendered by an IBCLC. That needs to change.

      I personally value what all kinds of breastfeeding helpers offer moms, from friends and family, strangers on the internet, the woman siting next to you at breastfeeding support group, to PCs, to CLCs, to IBCLCs, to FABMs and everyone in between. All are a vital part of the breastfeeding care “team”. We DO need to work together, Helen. I think we need to bridge the gaps instead of creating divides. We need to bring more women in under served communities into the conversation, and especially into the lactation profession. We need to be honest about the differences in breastfeeding support training/education, and respect those differences. We need to be proponents of providing ALL levels of breastfeeding support to all women who desire to breastfeed. We need to actively campaign to get more women involved in breastfeeding support, and have the financial backing to make it happen; wouldn’t it be great to be able to provide scholarships and mentors to women who wish to become IBCLCs? If we put as much energy into building support networks as we (collective) do into defending our own “credentials”, there is no telling what we could do.

  • […] 1. Don’t allow access to breastfeeding support to be limited! Please act today!  You may be happy to learn that we’re quite serious on this point, and plan to release a more formal statement next week. […]

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