Advancing Policy from the Private Sector (Week 8)

Why Private Sector?

With respect to PAMS, the advancement of legislative policy is not likely to be desired by those who choose to participate. When legislative efforts to support lactation fall short, or do not survive the policy process, and in light of the general mistrust and lack of understanding of the nuances of lactation, it isn’t any wonder. Where many involved with PAMS would like to see policy is at the level of the private sector professional organization, particularly those representing lactation consulting, lactation and human milk medical research and education, nursing, and obstetrics. Private organizations aligned with these specialties are uniquely positioned to support families in making informed decisions regarding specific practices associated with PAMS.

The realities of implementation of policy, no matter the source, are that private sector organizations have a significant role to play. Longest (2013) breaks the selection of an organization as the conduit for policy implementation into two steps (1) goals and objectives of the policy in question should find sympathy within the target organization and (2) the necessary resources (from authority to financial means) exist within the selected sympathetic organization. Due to the dedication of the American Academy of Nursing’s reputation, National driving of policy regarding breastfeeding in a professional and consultative role, and a significant commitment of time and resources to lactation and human milk policy, this organization fits well within the criteria established by Longest.

PAMS Policy Implications for Lactation Professionals

Lactation and by extension PAMS support frequently intersect with care providers wearing multiple hats while executing their practice and providing support. It is my great fortune and pleasure to have the opportunity to discuss intersection of private policies regarding lactation support and PAMS with Elizabeth Brooks, JD, IBCLC, FILCA. Brooks has been involved in policy making and implementation in leadership roles for the International Lactation Consultants Association (currently as President), as well as the United States Breastfeeding Counsel.

Most of the front-line, first contact lactation support persons are Internationally Board Certified Lactation Consultants (IBCLC), operating under the private guidelines for conduct and accreditation of the International Lactation Consultants Association (ILCA). Because many IBCLCs are also registered nurses frequently working within hospital systems, understanding the significance of policy from the American Academy of Nursing (AAN), the ultimate goal of the labors of this blog, on the practice of IBCLCs is important.

According to Brooks, “No IBCLC “needs” a policy to tell them how to work with clients or patients.  They have the International Board of Lactation Consultant Examiners (IBLCE) Code of Professional Conduct, IBLCE Scope of Practice , IBLCE Clinical Comptenices and ILCA Standards of Practice that are authoritative practice-guiding documents.  We can add in the International Code [for marketing breastmilk substitutes] if they are in a country where it is legislated, or works in a facility seeking to obtain/retain Baby Friendly designation.  If the practice or facility where an IBCLC works has a policy on any aspect of clinical care or decision-making [such as a policy from the AAN adopted by a facility], then the IBCLC will be bound by those “extra” practice-guiding documents that spring from conditions of employment.” Specific to IBCLCs in private practice faced with how to address PAMS, it is a matter of maintaining sensibilities surrounding liability of finance, legal, and professional natures. “Private practitioners — even solos — ought to have a policy and procedure manual guiding all aspects of their work as allied health care providers.”

Closing Thoughts

It is evident that IBCLCs, due to diverse practice settings, are likely to require tailored support for individual implementation of any polices regarding PAMS. Bearing this in mind, the recommendations entered into the policy development regarding PAMS have been selected and worded specifically to provide clarity of purpose and intention. This, it is sincerely hoped, will facilitate the adoption and dissemination of the policy even in light of the already existing complexity of IBCLC and RN practice.


Longest, B. B. (2010). Health policymaking in the United States (5th Ed.). Chicago, IL: Health Administration Press.

E. Brooks. Personal communication March 3, 2014.


2 thoughts on “Advancing Policy from the Private Sector (Week 8)

  1. Angie, your post is very timely for me as I have shared with you in a previous post. Currently, the clientele I serve participate in PAMS on a very informal basis, e.g. “Is it OK if I give my extra milk to my sister/cousin/friend who doesn’t have enough or vice versa. But as the disadvantages of commercial formula supplementation continue to be publicized in the media and more hospitals become Baby Friendly, more women will seek alternatives and may not have a known donor/recipient. IBCLCs may not need a policy, but it is certainly an advantage to have access to one when you feel the need to justify the information you are providing to a mother who is interested in PAMS. As more studies come to light on the safety of PAMS vs formula, I am confident more women will be asking for information. You are definitely on the curl of the wave!

  2. It is an exciting and terrifying place to be! Particularly for those, such as yourself, who are not in private practice, it is certainly a safety net if not a necessity to have SOMETHING to refer back to. It feels as though nothing I do is fast enough, but I wonder if it is possible to get it done any faster than it is going? It is so encouraging to me to hear about the existing progress you have in improving support for lactation and access to health information. Because California is a driving force for national policy regarding labor and treatment of disparity populations, yours is a critical state to watch for signs of change, as that signals the changing of tides, so to speak. The momentum for Baby Friendly is fantastic, we have one hospital that has achieved BFH status and 3-4 more in progress. One of these hospitals has been an incredible place to work with regarding infants with supplementation needs bringing in donors from the community. Their policy is that families have the right to feed their babies, and the hospital has a responsibility to support that in a responsible and ethical manner. The nursing and NICU staff have worked with recipients to store and handle milk, and donors have been amazing stepping up to provide documentation of their health status. It is a point of pride for them to be “worthy” of hospital acknowledgement. Seeing this work, and perusing literature from developing countries with similar functions makes me wonder why it has taken so long for this to verge on viability as a means of supporting access to human milk.

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