On April 17, 2026, the Department of Healthcare and Family Services in Illinois published a proposed update to its Medical Assistance program. Within the proposal were suggestions to change which lactation support provider types are eligible for reimbursement and their maximum fee schedule rates (1).

Alongside ALPP's colleagues from HealthConnect One, ten total comments were submitted within the comment period (ending June 1, 2026) to address the proposed changes. ALPP's initial comments and the Department of Healthcare and Family Services responses from August 27th, can be found below:

Public Comment: The proposed rule recommends coverage of lactation service visits within the first 3 weeks following childbirth, and a comprehensive visit within 4-12 weeks postpartum for individuals eligible for medical assistance. However, this coverage is not nearly enough to support families to meet their breastfeeding goals. Please consider amending this rule to cover between 9-12 or more visits postnatally with lactation support providers.

HFS Response: The Department has considered these comments. We apologize for the error in the description of the rulemaking in the first notice. The proposed rule under 140.926 does recommend lactation services visits during pregnancy and during the 12-month postpartum period beginning on the last day of the pregnancy.

Public Comment: As the rule is currently written, only three types of lactation support providers' services are included. This limits other types of providers' availability in our communities that can provide support for birthing families. As evidenced by the U.S. Breastfeeding Committee’s (“USBC”) Lactation Support Provider Descriptor Chart, (1) lactation consultants, lactation counselors, lactation educators, breastfeeding specialists, and peer counselors all provide necessary support for families who are hoping to breastfeed. All these provider types of work within their own Scope of Practice and readily refer families to other provider types when needed. All these provider types must be reimbursed by Illinois’ Medicaid program to increase access to care for families. Please consider amending this rule to include all lactation support providers listed on the Descriptor Chart published by the USBC. That way, all these qualified professionals will be covered by Medicaid in Illinois and eligible for reimbursement, thus increasing access to equitable and appropriate care.

HFS Response: The Department has considered this comment. The suggested change conflicts with the approved CMS State Plan Amendment which allows lactation consultant support services to be provided by an International Board Certified Lactation Consultant (IBCLC), Certified Lactation Counselor (CLC), and Certified Lactation Specialist (CLS).

Public Comment: Strongly recommends coverage for lactation services delivered across multiple settings, including hospitals, birthing centers, home visits, community-based settings, WIC clinics, healthcare offices, telehealth platforms, and support groups (online or in person). Families deserve flexible, accessible care models that meet them where they are. We support the recommendation from the World Health Organization that the duration of this covered benefit should be provided in the antenatal period and up to 24 months or longer.

HFS Response: The Department has considered these comments and may consider the change in a future amendment. The current language of 12-month postdelivery is consistent with other related maternal/child services, including postpartum care. Lactation services can be provided via telehealth, office, home, hospital, and birth center, per the Provider Notice issued on December 19, 2024.

Based on these responses, it appears that no additional revisions are being incorporated relating to lactation support. Future advocacy from all types of Lactation Support Professionals to update the CMS State Plan could be pursued in order to influence change and expand access to all types of lactation support in Illinois.

Sources:
1) https://www.ilsos.gov/content/dam/departments/index/register/volume50/register_volume50_16.pdf