Two new lactation billing codes take effect in January 2027, and the First Food field has spent this month working through what they mean. The U.S. Breastfeeding Committee (USBC) published guidance on the key issues and said it was preparing its own comment to CMS. Dr. Emily Hannon, MD, IBCLC, FAAP, shared the view from inside a pediatric practice. She is a pediatrician at Western Wake Pediatrics in Cary and the American Academy of Pediatrics Chapter Breastfeeding Co-Coordinator for North Carolina, and she was part of the group that worked with the AMA to create these codes. We are sharing both perspectives here.
The problem these codes solve
The Affordable Care Act promised coverage for lactation support in 2010. It never created a way for a medical office to bill for it. According to Dr. Hannon, practices have used workarounds for years, none of them correct. She has watched many pediatricians decide against hiring an IBCLC because they could not cover the salary with no payment coming in.
What the codes do
Two new CPT codes (978XX and 978X1, final numbers still to come) take effect in January 2027. According to Dr. Hannon, they let a physician, nurse practitioner, or physician assistant bill for lactation care provided by a lactation consultant employed in their office. They can be used on the same day as a medical visit, or on a day with no medical visit as long as the supervising provider is in the office.
What the numbers mean
Much of the worry online centers on the low value attached to the first code. According to Dr. Hannon, that number does not measure the lactation consultant’s work. It measures the two to three minutes the physician spends hearing the consultant’s report. The rest of the payment is practice expense: the consultant’s time, the infant scale, the chair, the pillows, the supplies.
USBC’s guidance makes a similar point: a practice-expense-only code does not mean the time is unpaid. USBC also asks CMS to look at whether the valuation reflects the skilled work that continues past the first 30 minutes of a visit.
The RN question
Lactation consultants have never existed as a staff category in the federal payment system. CMS has to price the new category against an existing one, and it proposed the registered nurse rate. Dr. Hannon and USBC agree on the most important point: using RN wages as a pricing comparison does not mean a lactation consultant must be an RN. The rule asks only that qualifications be recognized by a professional society or other appropriate source.
Where they differ is emphasis. USBC encouraged the field to tell CMS that the lactation workforce is not the same as nursing and to keep the pricing question separate from the qualification question. Dr. Hannon’s concern is that if the field argues against the RN comparison itself, CMS may choose a lower-paid category instead.
Who can bill
According to Dr. Hannon, IBCLCs and other lactation support providers will not be able to bill these codes on their own, and those who bill directly should keep using their current code sets. She notes that only five states license IBCLCs independently, with Connecticut the most recent in July 2026. Physicians providing lactation care themselves will keep using standard office visit codes.
USBC reads the proposal as less settled. Its guidance says the rule does not clearly establish whether independently practicing lactation support providers can bill the new codes, and it has asked CMS to clarify what “directed by a physician or other qualified health care professional” means in practice. USBC also asks whether the structure unintentionally favors care delivered inside a physician practice. Its Lactation Support Provider Descriptor Table lays out the range of providers this affects.
Where we stand
This is one piece of the puzzle. It should open jobs for lactation support providers inside pediatric, family medicine, and OB/GYN practices. It does not address payment for the community-based and independent providers so many families rely on. That work continues, and we will keep pushing for reimbursement that reaches lactation support providers at every credential level.
The CMS comment period closed September 14. The final rule is expected later this fall, and we will share what it says.
Thank you to Dr. Emily Hannon, MD, IBCLC, FAAP, AAP Chapter Breastfeeding Co-Coordinator for North Carolina, for sharing her expertise, and to the U.S. Breastfeeding Committee and its Lactation Support Providers Constellation for their guidance to the field.