Advocating for IBCLC Coverage in ACA

Below is the text of my submission for Department of Health and Human Services to ensure coverage for IBCLC care in the Essential Health Benefits portion of the Affordable Care Act in the USA.  I modified the text suggested by the USLCA.  Please feel free to use my version in your own voice of advocacy!  Please note that the website appears capable of accepting comments from outside the U.S. and we would greatly appreciate if non-American IBCLC's would add their voice on our behalf!

Please state that insurance companies must cover the services of the International Board Certified Lactation Consultant (IBCLC) in the maternal and newborn section of the Essential Health Benefits (EHB). IBCLCs are allied health professionals certified through a rigorous credentialing process who possess the requisite skills to manage common and complex lactation management issues. Too many breastfeeding mothers lack access to the level of care that they need, resulting in fragmented care deferred to providers who may not have the training or expertise to handle complex lactation situations. See http://massbreastfeeding.org/landscape/ for a guide to lactation qualifications. This drives up the cost of and increases the number of health claims due to increased infant illnesses and conditions preventable by successful breastfeeding. Services of IBCLCs result in lower health care costs to insurers. The U.S. Surgeon General included in the 2011 Call to Action to Support Breastfeeding, the specific recommendation to provide reimbursement for IBCLCs independent of their having other professional certification or licensure. The Centers for Disease Control and Prevention use the IBCLC as a metric in its determination of the adequacy of breastfeeding support in its annual Breastfeeding Report Card. Because breastfeeding is the normal way to provide for the needs of a newborn human, its absence creates health risks which can affect the child for their entire life. State required benefits should include IBCLC services to improve the quality and value of the coverage that is available for EHB. Please include coverage of IBCLC services under Sec. 147.150 Coverage of essential health benefits. I strongly encourage Secretary Sebelius to expressly declare in the text of the final rule that health plans specifically state that coverage will be available for IBCLC services.