I commend Natalie and Holly for articulating a concern about the direction
that lactation consultation has taken in its history, embracing the medical
model over the mother-to-mother counseling model from whence it sprang.

I commend Lactnet for being an intelligent forum that encourages respectful
dialogue about issues.

So I will add my contrapuntal.

I agree.  The IBCLC profession *is* moving -- rapidly -- from its
mother-to-mother counselor roots.  It is embracing the medical model,
complete with its jargon of certification, licensure, scope of practice,
etc.  Like it or lump it, it's where we are.  It's why LLL started the idea
of the IBCLC profession: to handle those situations that required MORE than
a lay counselor.

And that is okay.  Because the IBCLC is the essential credential for
lactation support .... as an allied healthcare provider.  And an allied
health care provider is not a mother-to-mother counselor, like those
trained by LLL or (my roots) the Nursing Mothers' Advisory Council.

And so I will respectfully disagree:  I do not think the efforts by IBCLCs
to obtain licensure, as a measure of better reimbursement for and paid
recognition of their role **as health care providers** will diminish, one
whit, the fine role (indeed the crucial role) that peer counselors play.

Nurses are licensed, OB-GYNs are licensed, midwives are licensed,
pediatricians are licensed, neonatalogists are licensed, OTs are licensed,
SLPs are licensed, chiropractors are licensed, massage therapists are
licensed, acupuncturists are licensed.  Their role in the healthcare field
does not diminish the need for or role of the LLL Leader or WIC peer
counselor or any other kind of mother-to-mother counselor.  Adding
licensure for IBCLCs won't make a difference, either.

I disagree with Stanley Gross's article about licensure on one major
element:  he argues that "the generally stated purpose for licensing and
the primary justification for this use of the police power of the state is
to ensure quality in services offered to the public."

I argue that licensure is an exercise of the state's power **to protect the
public's health, safety and welfare.**  It is the "hook" by which the
states are allowed to legislate and regulate free (professional) trade: if
people are going to go around playing nurse, doctor, or midwife, affecting
the health of mothers and babies by the care given, we (the state) had
better make sure they have passed some minimal measures of competency.

And critically, if they can NOT demonstrate those minimal measures of
competency, we (the state) need a disciplinary and sanctions procedure that
allows us to wrench that license from the "lemons," so they don't go on to
misinform or indeed even harm more mothers and babies.

I don't think licensed IBCLCs will prevent mothers from finding and using
excellent mother-to-mother volunteers.  I do think licensed IBCLCs will be
able to be reimbursed for their services, making them attractive employees
to have on a hospital staff.  For the discharged mom with private
insurance, skilled lactation support is henceforth a benefit with NO
out-of-pocket expense for the mother, under the ACA.

Medicaid will ONLY reimburse licensed providers.  >50% of USA births today
are to mothers who are WIC-eligible and whose children thus are
Medicaid-eligible.  Without licensure, *no* IBCLC will be able to provide
care under the Medicaid-expansion portions of the ACA (which are a much
bigger part of that complex law than the private insurance requirements).
 That means an awful lot of women will not receive care from an allied
healthcare provider whose singular specialty is human lactation.

Tossing aside my admittedly-selfish reasons to find job security, decent
compensation for my skill, and a stable future for the IBCLC profession, a
very real concern is that those >50% moms ain't gonna be able to see me or
my IBCLC colleagues.

IBCLCs have tried certification as the primary route to establish
credibility and appropriate compensation.  It hasn't worked.  Indeed, in
2012 we find ourselves now with such a muddled and confused marketplace,
with so many Not-Quite-IBCLCs claiming they have the same training and
skills as IBCLCs, that mothers really ARE finding their "health safety and
welfare" is at risk.

I welcome thoughts on alternative routes to assure that mothers who require
it receive IBCLC care, and that IBCLCs are fairly paid for their time  and
service as allied heathcare providers.
-- 
Liz Brooks JD IBCLC FILCA
Wyndmoor, PA, USA

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