Public Comment Archive

USLCA takes its responsibility for the promotion of the IBCLC credential very seriously. We engage in every opportunity we can to bring the IBCLC credential to the attention of state and federal agencies and the makers of public policy. The following comments and testimony were provided by USLCA to help strengthen the image and enlighten policy makers on the importance of the IBCLC.

May 2016 – The US Preventive Services Task Force recently asked for public comments on its draft recommendations statement on breastfeeding.  The recommended change from “support and promote breastfeeding” to simply “support” breastfeeding was viewed by the USLCA Board to be a significant departure from the previous statement.  In addition to sharing the Call for Comments with our members, the USLCA Board also submitted a formal comment.  Click here to see USLCA’s submission.

September 2015-In response to the Center for Social Inclusion’s recent publication, Removing barriers to breastfeeding: a structural race analysis of first food, USLCA has submitted a letter to encourage future collaboration. Click here to read the submitted letter.

 July 2015-TRICARE USLCA has written a letter to TRICARE describing the services of the IBCLC and requesting that IBCLC services be added to TRICARE benefits. See the full letter here.

June 2015-Department of Health and Human Services USLCA has sent a letter to the Secretary of Health, Sylvia Burwell, emphasizing the importance of reimbursing services provided by the IBCLC under the ACA. See the full letter here.

November 2014-Healthy People 2020 public comments regarding adding additional objectives to the Healthy People 2020 targets, November 2014. USLCA recommended adding the following objective to the Healthy People 2020 Maternal, Infant and Child Health Objectives:

Increase the proportion of breastfeeding mothers who have access to the professional services of an International Board Certified Lactation Consultant

October 2014-Joint Commission, The Joint Commission is developing a new optional certification program for hospitals that will focus on high-value requirements for mothers and newborns that have been assessed as clinically uncomplicated.

The Perinatal Care certification will provide an independent evaluation of an organization’s prenatal, intrapartum, and postpartum care services, while more fully addressing all stages of this specialty service. USLCA provided comments which recommended that in order to be recognized as a certified perinatal center, the facility must provide access to International Board Certified Lactation Consultants. The facility must also follow the IBCLC staffing recommendations as promulgated by USLCA.

October 2014- United States Preventive Services Task Force, October 2014. Comments provided on the draft plan on primary care interventions to promote breastfeeding. USLCA provided the following comments: The United States Lactation Consultant Association is pleased to provide comments on the draft research plan on primary care interventions to promote breastfeeding. Under the section entitled “Interventions” and in the text that reads,

  • “Interventions may be conducted by, but are not limited to: lactation consultants, nurses, peer counselors, midwives, doulas, or physicians”

It is important that during your perusal of studies looking at the type of providers who deliver lactation services, that the term “lactation consultants” be reserved exclusively for those who hold the International Board Certified Lactation Consultant (IBCLC) credential. The term “lactation consultant” is not a protected term, with many supporters of breastfeeding being referred to as a lactation consultant but possessing no more than several days of didactic training compared to the rigorous preparation of an IBCLC. Studies should clearly define whether the lactation consultant is an IBCLC or not. Numerous research articles have shown the importance of the IBCLC on the positive outcomes of initiation, duration and exclusivity of breastfeeding. Holders of other lower tier certificates should be clearly defined as counselors, educators, specialists, etc., and not be lumped in with those possessing the higher tier IBCLC credential. This better delineates the effects of individual providers of lactation services. Clear delineation of lactation service providers aids policy makers, insurers, employers, hospitals, and communities in providing the level of lactation care needed by mothers and babies.

August 2014-Title V Maternal and Child Health Services Block Grant to States Program: Guidance and Forms for the Title V Application/Annual Report, August 2014. USLCA comments recommended that  access to an International Board Certified Lactation Consultant (IBCLC) should be available through performance measure number 9 and Title V programs and the Maternal Child Health Bureau would benefit from having on staff an International Board Certified Lactation Consultant (IBCLC) who is responsible for assessing and assuring that comprehensive lactation care and services are available within Title V activities. For USLCA comments see Title V Block Grant comments 2014

March 2014-Federal Trade Commission Workshop on Examining Healthcare Competition

For comments provided by USLCA regarding the IBCLC and the professional regulation of healthcare providers see FTC healthcare provider regulation letter