ALPP submitted their letter of complaint on 7/22/2026. A copy of that later can be found below:

UnitedHealthcare
Attn: Reimbursement Policy Department
Commercial Reimbursement Policies
950 Winter Street, Suite 3800, Waltham, MA 02451

Re: Objection to revision of HCPCS S9443 in the June 2026 Commercial Reimbursement Policy Update Bulletin (Preventive Medicine and Screening Policy, Professional), effective September 1, 2026 To the Reimbursement Policy Committee:

In June 2026, a reimbursement bulletin was shared on the United Healthcare (“UHC”) website announcing that, as of September 1, 2026, the reimbursement structure for lactation care (code S9443) would be changing.(1) According to that bulletin, code S9443 can be considered for reimbursement when the mother is the patient, but will not be considered for reimbursement for an infant as the patient. In other words, code S9443 will be reimbursed for one session per date of service.

The Academy of Lactation Policy and Practice ‘s (“ALPP”) vision is a world where all families have access to quality, interdisciplinary, culturally sensitive lactation care, thereby promoting, protecting and supporting breastfeeding and lactating individuals around the world. This is only possible if there is access to all types of lactation support providers (“LSPs”), in various settings, across all geographic areas.

The American Academy of Pediatrics (“AAP”) states that breastfeeding and human milk are the normative standards for infant feeding and nutrition. The AAP supports exclusive breastfeeding for the first 6 months of life, and continued breastfeeding, along with appropriate complementary foods introduced at about 6 months, as long as mutually desired for 2 years or beyond. Human milk has a unique composition, with antimicrobial, anti-inflammatory, immunoregulatory agents, and living leukocytes, all of which contribute to the developing immune system of the child. Studies and meta-analyses have confirmed the association of 6 months of exclusive breastfeeding with decreased rates of lower respiratory tract infections, severe diarrhea, otitis media, and obesity in for infants and young children. Additionally, studies and meta-analyses have confirmed the impact of breastfeeding longer than 12 months on maternal health in decreasing maternal type 2 diabetes mellitus, hypertension, breast cancer, and ovarian cancer rates.(2)

A 2025 National Academies report made recommendations to promote and support breastfeeding, including a national strategy to ensure families have access to breastfeeding support. That same report concluded: “CMS, the Federal Insurance Office, and public and private payers should create and ensure comprehensive coverage and payment of breastfeeding services and supplies to guarantee equal access to [lactation support].”(3)

Payer policy guidance generated by the U.S. Breastfeeding Committee (“USBC”) suggests that, while the Affordable Care Act (“ACA”), enacted over a decade ago, was intended to be a sweeping reimagining of how public health infrastructure and healthcare delivery may be integrated [to help new families]…breastfeeding has been difficult for many insurers to fit into existing delivery models.”(4) UHC was one of several commercial insurance companies that began reimbursing for lactation support services in some states across the U.S following the ACA implementation. Despite a low reimbursement rate, this type of recognition for services that are desperately needed for new families was beneficial to both families and LSPs.

The recently announced policy coverage update, stating that UHC reimburse for lactation support services with the mother as the patient, but will not consider reimbursement for the infant, fails to recognize the science of the breastfeeding dyad, the comprehensive nature of lactation support and the role that breastfeeding plays for public health and wellbeing. As the Maine State Breastfeeding Coalition points out, “such a policy is nonsensical to the model of care that [lactation support professionals] offer, [as] few if any breastfeeding concerns do not involve the infant. Most sessions center around an assessment of the baby’s latch and milk transfer to the baby.”(5) Under this updated policy, UHC will not reimburse providers any longer for that crucial aspect of their work.

The (AAP) and the American College of Obstetricians and Gynecologists (ACOG) recommend assessing the mother-baby dyad as an integrated unit to support postpartum recovery, successful breastfeeding, and early childhood development.(6) The Academy of Breastfeeding Medicine (“ABM”) recommends that the dyad have an office or in-home visit with a lactation professional for the term infant.(7) These best practices require the infant to be present with the parent and the feeding to be observed. They also recommend continued follow-up for any infants with ongoing breastfeeding issues.

At a time when significant reimbursement challenges for healthcare professionals, and particularly for maternal and child health care providers, already exist and are causing major issues in accessing care, we need insurers to acknowledge the critical importance of breastfeeding and those professionals who support new families on their breastfeeding journeys. Chronic underpayment of lactation professionals has long been an issue, but further cuts to reimbursement rates threaten the ability of these professionals to continue their work all together. Our families cannot be successful with breastfeeding, and our babies cannot be given the best possible start to life, when insurance companies decide that reimbursing for this critically important work is no longer worth it.

ALPP urges UHC to reconsider this policy change, and to allow the use of CPT codes that cover both the mother and the baby in breastfeeding assessments and care, and that do not result in additional co-pays or deductibles.

ALPP requests that UHC withdraw its provision for excluding infant claims for CPT code S9443, and to continue to reimburse this code for both members of the breastfeeding dyad (mother and baby) when each is individually assessed. Alternatively, the creation of a new CPT code for a breastfeeding dyad assessment and support, which is reimbursed at a higher rate that code S9443, could serve as a solution.

ALPP requests the UHC withdraw the limit on one session per date of service language.

ALPP requests that UHC confirms that lactation support and counseling will continue to be covered by their health insurance policies as a preventive service without cost-sharing requirements.

ALPP would welcome the chance to engage in this conversation further, and thanks you for your time to reconsider these changes in the name of what is best for families and their babies.

Sincerely,

Ellie Mulpeter, MPH
Director, Academy of Lactation Policy and Practice
PO Box 2160
South Dennis, MA 02660

1. https://www.uhcprovider.com/content/dam/provider/docs/public/policies/comm-reimbursement/rpub/UHC-COMM-RPUB-June-2026.pdf
2. Joan Younger Meek, Lawrence Noble, Section on Breastfeeding; Policy Statement: Breastfeeding and the Use of Human Milk. Pediatrics July 2022; 150 (1): e2022057988. 10.1542/peds.2022-057988
3. https://www.nationalacademies.org/news/to-improve-breastfeeding-rates-in-us-report-recommends-creating-national-strategy-enacting-paid-federal-family-and-medical-leave
4. https://web.usbreastfeeding.org/External/WCPages/WCWebContent/webcontentpage.aspx?ContentID=2409
5. https://www.mainebreastfeeds.org/blog/united-healthcare-billing-changes
6. COMMITTEE ON FETUS AND NEWBORN; Hospital Stay for Healthy Term Newborns. Pediatrics February 2010; 125 (2): 405–409. 10.1542/peds.2009-3119
7. https://www.bfmed.org/protocols