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[your address and contact information]

[date]

[name and address of contact and Managed care plan]

Medicaid Managed Care Organization Plans Improvement: Offering expanded services of International Board Certified Lactation Consultants as preventive health services in plan benefit packages.

Dear [name]

I am writing to you as a representative of the United States Lactation Consultant Association (USLCA). I would like to discuss with you the addition of the services of International Board Certified Lactation Consultants (IBCLCs)as preventive health services to be included in Medicaid Managed Care benefit packages. The USLCA is a non-profit organization established to advocate for improved access to lactation care in the United States.

We urge [plan name]to include InternationalBoard-Certified Llactation Consultant services as a covered services. The provision of this cost-effective preventive service will aid your company to further its promotion of preventive care, as an expansion of services to their clients which includes additional federal matching funds for the company, and to achieve the associated health benefits and reduction in costs.

Breastfeeding is one of the most valuable medical contributions to infant health, associated with the reduced incidence and/or severity of various infectious diseases, a lower lifetime risk of diabetes, obesity, certain cancers, and asthma, and enhanced neurodevelopment.[1] Breastfeeding also imparts benefits to nursing mothers, including a reduced risk of pre-menopausal breast cancer, ovarian cancer, type II diabetes, hypertension, hyperlipidemia, metabolic syndrome, and cardiovascular disease.[2]Research shows that breastfeeding has the potential to lower U.S. healthcare costs by up to $13 billion each year on only a few infant illnesses.[3]

Current breastfeeding rates fall below recommended levels, particularly for low-income and minority mothers[4]many of who are or will be covered under the Medicaid Plans.Evidence shows that several practices in intrapartum medical care settings can significantly affect breastfeeding rates and the duration of breastfeeding among women. Medicaid mothers who experience contact with IBCLCs in the hospital are more than 4 times more likely to breastfeed at discharge.[5] Specifically, inclusion of and reimbursement for the services of lactation consultants can improve breastfeeding outcomes and contribute to improved mother and infant health outcomes.[6] According to the Surgeon General,

“International Board Certified Lactation Consultants (IBCLCs) are the only health care professionals certified in lactation care. They have specific clinical expertise and training in the clinical management of complex problems with lactation. Better access to the care provided by IBCLCs can be achieved by accepting them as core members of the health care team and creating opportunities to prepare and train more IBCLCs from racial and ethnic minority groups that are currently not well represented in this profession.”[7]

The U.S. Preventive Services Task Force (USPSTF) has given a recommendation of “B” for primary care preventions to promote breastfeeding, including pre- and postnatal breastfeeding education, formal breastfeeding evaluations undertaken by trained caregivers in the hospital, and out-patient care settings, followed by interventions to correct problems as needed.[8] Although coverage is not mandated we urge insurance providers to take this USPSTF recommendation into consideration, particularly given that private plans have been required to cover such services effective August 1, 2012, pursuant to the Patient Protection and Affordable Care Act (ACA).

These recommendations are consistent with the U.S. Surgeon General’s Call to Action to Support Breastfeeding, which included breastfeeding support as an important prevention strategy, and recommended insurance coverage for International Board Certified Lactation Consultant services in its list of actions.[9]

The federal Medicaid statute, as amended by the ACA, contains several provisions that enable states to reimburse, with the assistance of a one percent increase in federal matching funds, lactation consultants for the provision of lactation consultant services as preventive health care under their Medicaid state plans. For example, a state could include lactation consultant services within the optional benefits category for preventive benefits recommended by a physician or other licensed practitioner within the scope of their practice under State law.[10] In the alternative, including lactation consultant services within the definition of mandatory benefits categories, such as the inpatient hospital services benefit category,[11] or the benefit category for services related to pregnancy, delivery, and complications that may occur during pregnancy and up to 60 days post-partum.[12]

It should be noted that Medicaid providers often refer their patients to WIC Peer counselors for lactation support. WIC peer counselors are trained only to provide basic breastfeeding support.They do not have the skills and qualifications, nor is their scope of practice applicable, to the more complex situations that lie within the IBCLCs scope of practice. This leaves a significant population of mothers without access to the level of lactation care that they need. IBCLCs must adhere to prescribed Professional Standards (attached). WIC mothers participating in agencies with peer counselors that also have access to an IBCLC were more likely to initiate breastfeeding than participants of peer counselor agencies without such a consultant.[13]

In conclusion, in defining benefits package coverage, the USLCA urges Health [insurance company name] to recognize lactation consultant services as a covered service when rendered by International Board Certified Lactation Consultants (IBCLCs). We have attached several informative documents for your reference as you take into consideration our recommendation.

We appreciate your consideration of our comments and look forward to working with you to ensure that your company is able to reap the full public health and economic benefits associated with integrating International Board Certified Lactation Consultant (IBCLC) services into these benchmark benefits.

Sincerely,

Attachments

Containing Health Care Costs, 2nd Edition

IBLCE Professional Standards

Surgeon General’s Call to Action to Support Breastfeeding

[1]American Academy of Pediatrics, Policy Statement: Breastfeeding and the Use of Human Milk, Pediatrics, 115(2):496-506 (Feb. 2005).

[2]A.M. Stuebe ,E.B. Schwarz , The risks and benefits of infant feeding practices for women and their children. Journal of Perinatology.2010 Mar;30(3):155-162.

[3]M Bartick and A Reinhold, “The Burden of Suboptimal Breastfeeding in the United States: A Pediatric Cost Analysis,” Pediatrics 125, no. 5 (2010): e1048-e1056. Estimated savings if 90% of U.S. families complied with the medical recommendations to breastfeed exclusively for 6 months.

[4]M.M. McDowell, J. Kennedy-Stephenson, Breastfeeding in the United States: Findings from the National Health and Nutrition Examination Survey, 1999-2006, NCHS Policy Brief No. 5 (April 2008), available at:

[5]BC Castrucci et al. A comparison of breastfeeding rates in an urban birth cohort. Journal of Public Health Management. 2006;12:578-585.

[6]Thurman SE,Allen PJ. Integrating lactation consultants into primary health care services: are lactation consultants affecting breastfeeding success? Pediatric Nursing.2008 Sep-Oct;34(5):419-425.

[7]U.S. Department of Health and Human Services. The Surgeon General’s Call to Action to Support Breastfeeding. Washington, DC: U.S. Department of Health and Human Services, Office of the

Surgeon General; 2011.

[8]US Preventive Services Task Force, Primary Care Preventions to Promote Breastfeeding,

[9]U.S. Department of Health and Human Services. The Surgeon General’s Call to Action to Support Breastfeeding. Washington, DC: U.S. Department of Health and Human Services, Office of the

Surgeon General; 2011.

[10]SSA § 1905(a)(13).

[11]SSA § 1905(a)(1).

[12]SSA §§ 1902(a)(10)(C)(ii)(II).

[13]Yun S,Liu Q,Mertzlufft K,Kruse C,White M,Fuller P,Zhu BP. Evaluation of the Missouri WIC (Special Supplemental Nutrition Program for Women, Infants, and Children) breast-feeding peer counseling program. Public Health Nutr.2010 Feb;13(2):229-237; Grummer-Strawn LM,Rice SP,Dugas K,Clark LD,Benton-Davis S. An evaluation of breastfeeding promotion through peer counseling in Mississippi WIC Clinics. Maternal Child Health Journal.1997 Mar;1(1):35-42.