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To Governor Cuomo,

On behalf of the U.S. Lactation Consultants Association (USLCA) I am contacting you concerning professional lactation care in New York. I am pleased to learn that bill S3387 has passed to allow coverage of lactation services without referral to the residents of New York.

As the leading professional association in the U.S. advocating for the advancement of the lactation profession, we want to specifically address a current perception that the lactation care providers included in the bill, specifically, the International Board Certified Lactation Consultant (IBCLC) and Certified Lactation Counselor (CLC) are equivalent. Simply said, they are not, and we ask that the bill be vetoed and re-written to include clarifying language, highlighting the differences in the level of care each provider can deliver to avoid inadvertently blurring the lines.

Even within the profession we are aware that the titles used to identify the different categories of lactation care providers are confusing. It is, however, important to the current bill in New York and to any future legislation regarding lactation care, that policymakers have more clarity regarding the distinctions.

While all lactation care providers serve a valuable role on the healthcare team, the preparation and training required to become an International Board Certified Lactation Consultant (IBCLC) and the resulting expertise of IBCLCs is far more rigorous than any other lactation care certification currently available in the United States, including but not limited to the Certified Lactation Counselor (CLC) designation.

The IBCLC credential requires completion of 14 college-level health science courses, lactation-specific education, and a minimum of 300 supervised clinical hours. Conversely, requirements of the CLC, for example, do not include any prerequisites, even a high school diploma, to take the CLC five-day course and sit for the exam, and no hands-on clinical training is mandated or even recommended. These differences result in a significant gap between the expertise of an IBCLC and that of a CLC. Attached is a clarification document, published by USLCA to help provide some additional detail.

A CLC is certified to provide basic lactation care, breastfeeding education and some care management. Often though, families have more complicated breastfeeding issues that require the specialized, clinical expertise of an IBCLC. Some examples include preterm birth, birth complications, maternal physiological issues, and babies with special feeding needs. Conversely, IBCLCs are trained and educated to assess and manage lactation for a vulnerable population of new parents and infants. The IBCLC lactation consultation includes conducting a detailed history and physical exam; full feeding observation and documentation of milk transfer; analysis of physical, social, emotional and environmental risk factors and complications that inhibit adequacy of the breastfeeding process; reporting to the primary healthcare team; and referral for specialized services when warranted.

The American Academy of Pediatrics recommends exclusive breastfeeding (EBF) for 6 months and continued breastfeeding past 1 year of age. According to the Center for Disease Control and Prevention’s Breastfeeding Report Card, less than half of New York infants are breastfed exclusively for even 3 months and only 22% of New York babies are attaining the goal of EBF at 6 months due to the difficulty in accessing appropriate lactation care in a timely fashion. With the wide variation of needs of both parent and baby, lactation care providers across the professional spectrum have an important place in community health and on the healthcare team to accomplish public health breastfeeding goals.

As with other healthcare professions, the range in qualifications among lactation care providers should not be a barrier to care but should serve as a way to extend and expand breastfeeding support. By recognizing the breadth of providers by their appropriate scope of practice, those with more routine needs can be seen quickly for basic support and those with more complex situations can receive more specialized care by those trained to provide it.

Legislation that depicts equivalency between IBCLCs and CLCs pose a significant potential risk to the public. In the proposed language the equating and likening of differing certifications implicitly states that any lactation care situation involving a vulnerable baby and new mother, even the most complex, can be handled safely and effectively by any lactation care provider, whether they’ve had 5 days of training or years. This creates risk for both provider and patient: the provider because they are not adequately trained to handle complex clinical situations even though they are expected to do so as a credentialed provider, and mothers and babies because they receive care from a provider they believed had the knowledge and training to provide the level of care needed.

As with other professional categories of healthcare, there are differing levels of providers who contribute to patient care with varying qualifications and scopes of practice, among which there can be overlapping duties. For example, certified nurse practitioners, registered nurses, licensed practical nurses, medical assistants and medical assistant technicians may work together in physician offices. Often times, patients do not know the difference among them yet they each have limits to their duties and serve under a physician’s oversight. For the sake of families, the scope of practice that defines each level of service in healthcare must not become blurred in the minds of policymakers. Doing so presents tremendous risk with potentially significant consequences.

While USLCA strongly supports reimbursement for lactation care providers, we just as strongly urge you to evaluate and define the significant differences in the depth of training and expertise of IBCLCs compared to CLCs. For the health and safety of residents across New York and to protect all those who practice lactation care in the state, we ask that this important work lead to greater clarity, safer care and better health outcomes for mothers and babies.

Sincerely,

Danielle Harmon, MPH Executive Director USLCA

4410 Massachusetts Ave., NW #406, Washington, DC 20016 www.USLCA.org ● info@USLCA.org ● 202.738.1125