Ohio families rely on doulas and lactation support for safe, supported births and healthy babies—but HB 744 could unintentionally limit access to this essential care. If passed without clarification, this bill may classify normal, hands-on support provided by doulas, CST practitioners, and lactation professionals as regulated massage therapy—putting vital services at risk.

I am a Birth Doula, Certified Lactation Counselor (CLC), Community Health Worker (CHW), Craniosacral Therapist (CST), and Prenatal Educator. I have dedicated over eight years to supporting families in Northeast Ohio through pregnancy, birth, and the postpartum period. My work has positively impacted hundreds of families, helping them navigate these critical phases of life. I have obtained certifications from reputable organizations such as the Academy of Lactation Policy and Practice, the Ohio Board of Nursing, Birthworker Academy, Lamaze International, and more. 

I am deeply concerned that HB 744’s broad definition of “massage therapy” — which includes: "manipulation of soft tissue through the systematic external application of massage techniques including touch, exerting pressure on, stimulating with the hands, stroking, friction, vibration, percussion, kneading, stretching, compression, and rubbing, tapping, pounding, and joint movements within the normal physiologic range of motion... the external application of water, heat, cold, topical preparations," would unintentionally restrict essential, evidence-based care that we provide within our distinct professional scopes.

House Bill 744 may unintentionally disrupt the vital services I, and many others like me, provide. The current language of the bill lacks clear exemptions for International Board Certified Lactation Consultants (IBCLCs), Certified Lactation Counselors (CLCs), doulas, birthworkers and Other somatic or bodywork practices that primarily use light touch, energy-based methods, or movement education rather than deep tissue manipulation or vigorous
techniques.".

 These roles are essential in providing diverse support options to families during the childbearing year, and family seeking alternative therapies. Excluding clear exemptions could limit access to important services that improve maternity care outcomes, support maternal mental health, and promote positive birth experiences. Ohio House Bill 744 is intended to clarify regulations around massage therapy. However, as written, there is concern that the bill could unintentionally impact professionals who provide non-medical, supportive care involving touch—such as doulas, lactation professionals, and craniosacral therapists.

In Ohio, like much of the United States, maternal and newborn health outcomes remain a significant public health challenge. According to the Centers for Disease Control and Prevention (CDC), the U.S. has one of the highest maternal mortality rates among developed nations. Support from professionals like CSTs, IBCLCs, and doulas is proven to enhance these outcomes significantly by offering crucial education, hands-on support, and evidence-based care plans.

For many families, these certified professionals provide invaluable assistance in breastfeeding, pain management, and emotional support. Statistics reveal that doulas can reduce cesarean rates by up to 39% and increase the likelihood of a shorter labor and healthier babies. Additionally, lactation professionals are pivotal in promoting breastfeeding, leading to better health for infants and mothers alike.

Therefore, it is imperative that Ohio House Bill 744 includes clear exemptions for CSTs, IBCLCs, CLCs, and doulas, and other birthworkers ( Traditional Midwives, Birth Attendants) to continue their work without unnecessary legal and professional barriers. By advocating for these exemptions, we are supporting a model of care that emphasizes personalized support, informed choices, and overall improved public health outcomes.

I am writing to respectfully request explicit exemptions in House Bill 744 for Certified Craniosacral Therapists (CSTs), International Board Certified Lactation Consultants (IBCLCs) and Certified Lactation Counselors (CLCs), and Certified Doulas (including those certified by the Ohio Board of Nursing).

For Doulas: During labor, we routinely provide hands-on comfort measures such as sacral counter-pressure, hip squeezes, effleurage, and gentle hands on support. These are non-medical techniques taught specifically in doula training programs to help birthing women manage pain and improve outcomes. 

For Lactation Counselors (CLC/IBCLC):  The use of hands-on techniques to relieve plugged ducts, mastitis, engorgement, and to support better latch and milk transfer are core clinical tools. These specialized interventions, along with gentle techniques to improve oral-motor function, are performed daily within our internationally recognized scope of practice. Without an exemption, many of us would also lose access to advanced hands-on training.

For Craniosacral Therapists (CST): CST uses very light, subtle touch to support the body’s natural rhythms and self-corrective processes. It is not traditional massage and requires specialized training. Families frequently seek this gentle work for newborns to address breastfeeding difficulties, plagiocephaly, torticollis, colic, and birth trauma.

Without a specific exemption for practicing within our scope of practice, many of us would be forced to:

• Obtain a separate massage therapy license (which does not align with our training or scope and would create unnecessary financial and time burdens),
• Stop providing these essential services altogether.
• Reduced access to timely, in-person lactation support (especially critical in the first days and weeks postpartum);
• Increased risk of breastfeeding failure, early weaning, maternal pain, and infant failure-to-thrive;
• Higher healthcare costs from unnecessary formula supplementation, emergency visits, and potential readmissions; and
• A direct negative impact on Ohio’s already concerning maternal and infant health outcomes.

I respectfully urge you to amend HB 744 to explicitly exempt certified doulas, IBCLCs/CLCs, and CSTs when practicing within their recognized professional scopes. This straightforward change would protect public health, preserve family-centered care, and support Ohio’s efforts to improve maternal and infant outcomes.

Proposed Language:

"In section 4731.15 of the Revised Code, as amended:
(A) 'Massage therapy' means the systematic external application of techniques such as
touch, pressure, stroking, friction, vibration, percussion, kneading, stretching,
compression, rubbing, tapping, pounding, and joint movements within the normal
physiologic range, or the adjunctive use of water, heat, cold, topical preparations, or

mechanical or electrical devices, for the purpose of treating disorders of the human body
by manipulating soft tissue. However, 'massage therapy' does not include:

(1) Comfort or supportive touch provided by a doula, traditional birth attendant, or
non-licensed birth worker during labor, birth, or postpartum care, including but not limited
to sacral counter-pressure, hip opening techniques, or light effleurage for pain relief or
positioning assistance;

(2) The practice of craniosacral therapy, which involves subtle, non-invasive palpation
and gentle holding or light touch to evaluate and address the craniosacral system, when
performed by a practitioner trained through a recognized program and not advertised as
massage or soft tissue manipulation for therapeutic massage purposes;

(3) Other somatic or bodywork practices that primarily use light touch, energy-based
methods, or movement education rather than deep tissue manipulation or vigorous
techniques performed by a practitioner trained through a recognized program and not advertised as
massage or soft tissue manipulation for therapeutic massage purposes."

Read the bill here: https://www.legislature.ohio.gov/legislation/136/hb744

Understand Types of Regulation and Massage here: https://www.federationmbs.org/LegPak_2023_01.pdf