It's taken me some time to put together my thoughts on the lesser 
credential, but I'd like to share them. I am a CLC, and am just beginning 
practice, under the supervision of an IBCLC. I think there is tremendous 
value to this system, and hope it is the intention of IBLCE to strongly 
recommend, or better yet, *require* that all lesser credentialed 
individuals practice under the direct supervision of an IBCLC. I think it 
is OK to leave the degree of supervision up to the IBCLC - for example, if 
the individual is very competent and well-educated, the IBCLC may be 
satisfied with a weekly review of cases and/or chart review (like an NP 
practicing under a physician's supervision), while someone just starting 
out will need much more in-person supervision. We are fortunate enough 
that both me and the IBCLCs at our clinic are able to get paid during the 
time I am being fully supervised. Kathy Eng posted that she thinks this 
kind of situation will be rare, but why not shoot for the ideal? I mean, 
can an LPN practice without RN or MD supervision? Can a paralegal practice 
without the supervision of a lawyer? I don't know the answer, but I don't 
think so. Why not make IBCLC the same way? 
Two more thoughts:
First, IBCLC itself MUST incorporate some clinical competency standards. I 
could pass that test tommorrow, becuase I'm a good test-taker. I've had 
about 50 hours of direct clinical lactation experience, and over 100 L-
CERPS. I could pass the test, and if I worked maternity or somewhere there 
was someone to (unethically) sign off on my hours, I'd be IBCLC this 
summer - which I don't think is right. But I don't think practicing 
unsupervised for 2000 hours is going to improve my level of care either - 
I'll just keep doing the same stuff I've been doing. There needs to be a 
combination of mentoring AND assessment of clinical skills to the 
certification. The number of hours is meaningless without these things. 
And there are certainly individuals who could be at appropriate IBCLC 
skill-level with far fewer hours, if the hours were truly learning 
experiences, not just repetition of the same old stuff "learned" years 
ago. 
Second, here in Vermont, we are working towards licensure, which I believe 
is necessary. The fact that anyone (myself included) can use the 
title "Lactation Consultant" leads to the kind of confusion among 
consumers that degrades the profession. If the "lactation consultant" in 
the hospital told you one thing, the "LC" at your pediatrician's office 
something different, then the private practice IBCLC really doesn't have a 
leg to stand on as the authority in the situation. Someone can be 
an "assistant" or "student" LC, or a "breastfeeding assistant" or whatever 
the lesser credential is called, as long as it's not something like "CLC" 
that is so easily confused with IBCLC or RLC. This will have to progress 
state by state, but I encourage all U.S. IBCLCs to keep pushing for this. 
Freely confessing my ignorance, what states have already done this? What's 
the feedback? Were IBLCE credentials accepted as sufficient for state 
licensing? 

OK, the windbag is done. I support the lesser credential as a formalized 
training system. It also provides an important mechanism for organizations 
that simply can't have 10 IBCLCs on staff, but can manage to get 9 people 
through the lesser training with an IBCLC overseeing the work and 
consulting on difficult cases. This ensures at least a minimum standard of 
care from the lesser credentialed "assistants". Formalizing the heirarchy 
of levels of care, I think, can help clarify the mish-mash of titles to 
the public. 

Thanks for hearing me out! 
Kirsten Berggren, PhD, CLC
www.workandpump.com

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