I have pasted below the comments I sent to the IBLCE regarding the proposed
Code of conduct as they related to IBCLCs in the United States in
particular.  
This is an extremely important issue for IBCLCs. 

 

 

Dear Colleagues in IBLCE:

 

Thank you for the opportunity to comment on the proposed new Code of
Professional Conduct for IBCLCs. 

I am writing to you as an IBCLC working in private practice, in a physician
practice, and in public health. I am also Chair of the USLCA Licensure and
Reimbursement Committee. 

 

Regarding USLCA's work in advocating for licensure and reimbursement of
IBCLCs, we rely heavily on the published Professional Standards for IBCLCs.
Changes in these standards, including this proposed change to Code of Ethics
will affect our work since these standards have been shared widely with
legislative and administrative authorities in government, health and
insurance fields as evidence of the solid foundation for IBCLC
certification. Changes must not be made in a cursory manner. Should the new
document be adopted, I would like some information regarding the rationale
for these changes that I could share with these authorities who are already
considering the former documents. 

 

In general, I see the plain language in the new document is an improvement
in readability for anyone wishing to know about the IBCLC required conduct;
however I find some of the content changes troubling. 

 

Preamble 

I dislike the links to other documents in this paragraph. When we distribute
the current Code of Ethics to interested parties in advocating for the
IBCLC, they may only have a print copy and they would be unable to access
these other documents. Additionally, this would require those who do have
access to the embedded links to read four other documents in order to
understand our Code. If these documents are to be referenced, the relevant
text should be included within the Code of Conduct rather than links.  

 

The following statement seems erroneous to me, "IBLCE was founded to further
broad principles of human rights articulated in numerous international
documents stating that all members of society have the right to the highest
attainable standard of health, including the woman's right to breastfeed and
the child's right to be breastfed." The statement is followed by links to
four documents, two of which did not exist when IBLCE was founded. Though
the language doesn't technically say it was founded on these specific
documents, it reads that way and I think it is misleading.  

Additionally, it is always my understanding that IBLCE was founded to
provide a means of establishing the standard for the "well-trained lactation
professional", the "lactation consultant," and a means of identification of
the IBCLC certification as the gold standard for the profession.  The
"further broad principles of human rights" reads to me like an attempt to
advertise or lobby for the profession using social media marketing tactics,
rather than to define our professional responsibilities. 

 

"Encourages" as the verb used in this sentence "IBLCE encourages IBCLCs to
uphold the highest standards of ethical conduct."   weakens the requirement
to maintain the "highest standards". I think this sentence deserves a
stronger verb making adherence to these standards an obligation, not an
option. 

 

Of specific concern, is the removal of the following statements from the
Code of Ethics? 

a.        "The purpose of the International Board of Lactation Consultant
Examiners (IBLCE) is to assist in the protection of the health, safety, and
welfare of the public by establishing and enforcing qualifications of
certification and for issuing voluntary credentials to individuals who have
attained those qualifications. IBLCE has adopted this Code to apply to all
individuals who hold the credential of International Board Certified
Lactation Consultant (IBCLC)."

b.       And, "The International Board Certified Lactation Consultant shall
act in a manner that safeguards the interests of individual clients,
justifies public trust in her/his competence, and enhances the reputation of
the profession. The International Board Certified Lactation Consultant is
personally accountable for her/his practice and, in the exercise of
professional accountability, must."

 

These statements seem to be replaced with,

"To guide their professional practice, it is in the best interest of all
IBCLCs and the public they serve that there is a Code of Professional
Conduct which:

. Informs both IBCLCs and the public of the minimum standards of acceptable
conduct;

. Exemplifies the commitment expected of all holders of the IBCLC
credential;

. Provides IBCLCs with a framework for carrying out their essential duties;

. Serves as a basis for decisions regarding alleged misconduct"

 

This change has serious implications for the future of licensure for IBCLC
because it drastically weakens the IBCLC certification as a basis of
'consumer protection'. The entire new document now seems to have its focus
on the IBCLC rather than the "protection of the health, safety, and welfare
of the public". This is a serious problem as it relates to proposed
licensure legislation in several states where we have language that joins
licensure to the IBCLC certification for the purpose of public protection.
By writing licensure bills which require the IBCLC credential as the basis
for licensing, we can avoid the necessity of creating and administering a
separate exam and exam board for IBCLC licensing, thus saving appreciably on
costs of licensure fees which must cover the maintenance of the governing
board. Without this language, it would be cost-prohibitive for the small
number of IBCLCs in each state to support a licensing board. Therefore, it
is doubtful that licensure could be attained in any state.     

 

Under Definitions and Interpretations statement 1, "For the purposes of this
Code of Professional Conduct for IBCLCs, this document will be referred to
as the 'Code'." could create confusion.  The "Code" in IBCLC language has
always been used to refer to the "WHO Code". Could this be changed?? Perhaps
change to "Code of Conduct". 

 

Principle 1.  Provide services that promote, protect and support
breastfeeding

1.2 I like inclusion of this statement, "Provide care to meet clients'
individual needs that is culturally appropriate, evidence based,
comprehensive, and up to date." Sadly, I have noted more than a few IBCLCs
practicing without staying current. I would like to see the word "current"
in place of "up-to-date".

 

1.4 "Convey accurate, complete and objective information about commercial
products (see Principle 7.1)." Reference to 7.1 doesn't quite make sense to
me, what does that mean specifically?  How do we provide complete
information about products we may not have information about or personal
experience with? Are we expected to have detailed technical knowledge of
every pump, pillow, galactagogue and gadget on the market? I think the
former statement was more practical, "Provide information about appropriate
products in a manner that is neither false nor misleading."

 

1.5 I think there is a fine line between calling an action "personal bias"
and "an IBCLCs practical experience" as noted with legitimacy in the
definition of evidence-based. How would you explain the difference?

 

Principle 2. Act with due diligence

 

Under this section, it seems that the obligation to inform the client from
the former Code of Ethics has been left out. 

 

"11. Provide sufficient information to enable clients to make informed
decisions.

   18. Present substantiated information and interpret controversial
information without personal bias, recognizing that legitimate differences
of opinion exist."

 

I think it is important to keep these items in the Code of Conduct as
protection for the public and the IBCLC. Some health care professionals have
bias against certain information or alternative health care practices that
may be helpful to clients and these statements protect the IBCLCs right, and
obligation, to give evidence-based information, within our scope of
practice, that another health professional might suggest or require the
IBCLC withhold. Examples of information that might be withheld might,
existence of infant with a tight frenulum, use of herbal products or
acupuncture, use of test weights for estimation of intake at the breast,
etc.  

 

Principle 4. Report accurately and completely to other members of the
healthcare team

The articles in this section are ambiguous do not clarify the obligations to
report.

c.        Is there an obligation to report to the mother and / or baby's PCP
"every" encounter, initial and follow-up? For example, an IBCLC in private
practice may not always send a report of her visit. Is that acceptable? What
if a mother does not have any PCPs? Or does not want her visit reported to a
PCP? 

d.       Can the IBCLC report only when the plan of care changes with an
ongoing problem? Or periodically? 

e.       Can the IBCLC report only to the mother's PCP if it is primarily a
maternal issue, for instance plugged milk duct? Or only to the baby's PCP if
it is a sucking problem when mother has no problems?   

 

 

Principle 7.  Uphold the professional standards expected of an IBCLC

The requirement to report unethical practices has been removed. What is the
rationale for this?

"Accept the obligation to protect society and the profession by upholding
the Code of Ethics for International Board Certified Lactation Consultants
and by reporting alleged violations of the Code through the defined review
process of the IBLCE."

 

I hope you will take these comments into serious consideration prior to
changing the current Code of Ethics. 

Thank you for your time and attention to this matter.

 

Sincerely,

 

Judith L. Gutowski, BA, IBCLC, RLC

 


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