Although I haven't read recent JCAHO standards, I'll bet  they don't say
anything about lactation consultants needing to be RN's.  Other members of
the health care team make assessments all the time--e.g. social workers,
OT/PT, registered dieticians, etc.  Remember, you are assessing
breastfeeding,  not the entire patient, the same as the social worker is
assessing the patient's strengths and social support systems, and the
registered dietician is assessing the patient's nutritional status.  An RN is
supposed to make an overall assessment of the patient's physical, emotional
and  social status and then based on the assessment make a plan of care. This
plan of care could include calling the lactation consultant. In the setting
where I work we have  all RN LC's because many of the babies we work with are
very sick. We don't make  a formal physical assessment of the baby, but we
need to understand the physical condition and the ramifications of feeding
methods. We also need to recognize and respond when an infant deteriorates
during a feeding or even make a decision about whether it is safe to put baby
to breast.

But back to JCAHO--I think what they will want to see is that breastfeeding
support is available from a board certified lactation consultant, that you
make a breastfeeding assessment and that you are able to make and communicate
a plan of care.  Ask your manager how it is that you would not fall into the
same category as OT/PT, Reg. Dieticians, social workers, chaplains, etc.
What JCAHO loves is a multidisciplinary plan of care and having an IBCLC
contribute to that should make them happy.

Kathy Boggs, RN, IBCLC
Mountain View, CA

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