We are writing on behalf of the undersigned which includes International Board Certified Lactation Consultants (IBCLCs), many of whom are or have been in-network providers with Aetna as well as patients- many of whom are Aetna customers. 

We are reaching out to request immediate reconsideration of recent changes affecting coding and reimbursement for lactation care—changes that severely restrict access to lifesaving services for mothers and infants and undermine the value of a highly trained healthcare workforce.

IBCLCs Are Qualified Healthcare Providers
The International Board Certified Lactation Consultant (IBCLC) credential is the gold standard in lactation care, globally recognized and held by over 35,000 professionals in more than 100 countries. IBCLCs are:

• Required to complete up to 1,000 clinical hours of supervised lactation care before sitting for the board exam.
• Certified only after passing a rigorous, psychometrically validated exam governed by the International Board of Lactation Consultant Examiners (IBLCE).
• Bound by ethical and practice standards, with recertification every 5 years and ongoing continuing education.

Unlike peer credentials such as Certified Lactation Counselors (CLCs), IBCLCs are clinical providers trained to manage complex breastfeeding problems, co-morbidities in mother or infant, and can work autonomously within multidisciplinary care teams. Though many IBCLCs also hold clinical licenses (RN, LPN, MD, etc.), licensure is not a universal standard, nor required for recognition under CMS’s Qualified Healthcare Provider framework. In fact, most U.S. states do not offer licensure for IBCLCs, despite their medical role.

Recent Coding Restrictions Jeopardize Access to Care
On September 1, 2024, Aetna implemented a policy disallowing IBCLCs from billing Evaluation & Management (E/M) codes (99201–99215). These codes had been appropriately used by IBCLCs in alignment with their scope and training.

On April 23, 2025, the Benefits Guidance Statement that clarified that codes 99341-99350 (home visit codes) and 99401-99404 (counseling services) are also not covered for lactation counseling services, leaving providers with no viable billing pathway for individualized care. We have already begun seeing denials that reference these exclusions—denials that, in our view, should be reserved for non-clinical counselors, such as CLCs, whose training and scope are not equivalent.

Lactation Care Is Preventive, Cost-Saving, and Life-Preserving
IBCLCs provide preventive healthcare services that directly reduce:

• Maternal mortality and morbidity, through improved postpartum recovery and infection prevention.
• Infant hospitalizations, including reductions in necrotizing enterocolitis, sudden infant death syndrome (SIDS), and severe respiratory infections.
• Healthcare costs, by supporting exclusive breastfeeding, which saves an estimated $13 billion per year in the U.S. (Bartick & Reinhold, 2010).

At a time when the U.S. maternal mortality rate is among the highest in the developed world—over 32.9 deaths per 100,000 live births in 2021, and rising among marginalized communities—removing access to skilled lactation support is an alarming policy direction.

Urgent Requests
We respectfully request the following actions be taken immediately:

• Reinstate coverage for E/M codes 99201-99215, especially 99341-99350, and 99401-99404 for IBCLCs when used within scope, as has been historically allowed and aligned with CMS definitions of clinical provider billing.
• Distinguish IBCLCs from non-clinical lactation counselors in medical policy language. Denials for “lactation counseling not covered” must not apply uniformly across all lactation codes & professionals.
• Globally increase the reimbursement rate for code S9443 (lactation classes). Currently reimbursed at $60–$71.50 per session, this amount does not reflect the extensive and specialized nature of care delivered.

Given that each visit averages 60–90 minutes per dyad, we ask a minimum rate of $125 per unit of s9443, which aligns more appropriately with the scope, duration, and outcomes of these services and is similar to other insurance providers reimbursement rates.
 
We, the undersigned IBCLCs, are committed to upholding the highest standards of perinatal care and respectfully urge your office and Aetna leadership to review these decisions with a full understanding of their clinical, ethical, and financial implications.

We welcome the opportunity for further discussion and are ready to provide additional data, including outcome-based studies and cost analyses.

Sincerely,