Part of my responsibilities as the director of our hospital's education
department is assessing, documenting, and evaluating competency of health
care providers-licensed and unlicensed.  I provide consultation to the many
departments that make up our hospital, including those with personnel that
are unlicensed and set the competency standards for the hospital.

For example, how many of you have been touched by a nursing assistant,
scrub tech, or phlebotomist when they were providing you with care?  They
are unlicensed assistive personnel (UAPs) and are critical members of the
health care team.  They have demonstrated competency in their area of
expertise, much like a CLE, CBE or IBCLC would.  This is a Joint Commission
(JCAHO) requirement.

 While I understand a WIC clinic may or may not be JCAHO accredited, a
critical element of competency for these UAPs includes TOUCHING PATIENTS!
Caring for people, whether you are a nail technician, massage therapist or
lactation consultant requires touching people from time to time.  Even as
an educator, we touch people.  You ask permission beforehand!  Common sense
tell us that if you are receiving a manicure, getting a massage or being a
consumer of health care may involve some TOUCHING!  To avoid liability, we
have the pateint sign a consent for treatment and get informed consent.

There are times when touching the mother and or baby are essential in
providing care to mother and child, whether you are licensed or not.
Informed consent is informed consent, regardless of your licensure or
competency status.  You ask permission before you touch.

The premise that a CLE or CBE that is not licensed can't touch a patient is
ridiculous.  During your certification process you have demonstrated a
minimal level of competence so that you may use those credentials.  I'm
sure there are finger sticks being done in the WIC office.  Who is doing
it?  Are THEY licensed?  What is the problem with an unlicensed CLE or CBE
who is assisting a mother with breastfeeding touching her or her baby, if
she has given you permission to do so?

JMHO, this supervisor needs to worry about something else, like funding for
breastfeeding promotion or reimbursement for LC visits.

Am I just not getting this???  Dumbfounded on a lovely Kansas Day!

Maurenne Griese, RNC, BSN, CCE, CBE
Manhattan, KS  USA