On September 1, 2026, UnitedHealthcare is changing how it pays for lactation care, and if you don’t know what HCPCS code S9443 is, that’s fine, because the people making this decision clearly don’t either.
Here’s what’s happening. In UnitedHealthcare’s June 2026 Commercial Reimbursement Policy Update Bulletin, buried between allergen testing and vitamin B12, is a revision to S9443 (the code for lactation support delivered by a non-physician provider, which is to say, us). Two changes:
- They will no longer reimburse S9443 when it’s billed for the infant. Only a claim listing the mother as the patient will be paid.
- They will pay for only one session per date of service.
If you’ve ever done a lactation consult, you already see the problem. We don’t treat one patient. We treat two. The baby is weighed, examined, assessed, and counseled on as a distinct individual with their own findings and their own chart. A shallow latch starts with the baby and ends with the mother in pain. A transfer problem can be the parent’s supply, the baby’s oral motor function, or both. You cannot assess half a dyad and call it lactation care. UnitedHealthcare is proposing to pay us to do exactly that.
Their stated reason is “alignment with CMS.” That rationale falls apart the moment you look at it. S9443 is an HCPCS Level II “S” code, a category that exists because Medicare doesn’t price or cover it. Medicare doesn’t cover lactation services because Medicare doesn’t insure the population that lactates. There is no CMS dyad-billing policy for S9443 to align with. The CMS framing is a costume.
And it runs straight into UnitedHealthcare’s own obligations. The Affordable Care Act requires non-grandfathered plans to cover comprehensive lactation support and counseling without cost-sharing. UnitedHealthcare’s own Preventive Care Services medical policy (MP.016.58) opens by acknowledging exactly that. The April 2025 USPSTF “B” recommendation on interventions to support breastfeeding sits right on top of it. A policy that pays to counsel the parent while refusing to assess the baby who can’t transfer milk is not delivering a comprehensive preventive benefit. It’s delivering a discount on one.
Here’s who pays for that discount: families. When reimbursement stops covering the work, IBCLCs leave networks, shorten visits, or stop seeing UnitedHealthcare families altogether. The window this hits (the first weeks postpartum) is exactly when skilled help prevents early weaning, failure to thrive, dehydration, jaundice, mastitis, and hospital readmissions. There’s also a gap nobody at UnitedHealthcare seems to have thought about: in plenty of families, only the baby is covered by UnitedHealthcare. Deny the infant claim and those families get no covered lactation care at all.
So we’re going to say something about it. Loudly, in writing, from a lot of directions at once.
Source Documents
Don’t take my word for any of this. Here are the primary sources:
- The proposed change: UnitedHealthcare Commercial Reimbursement Policy Update Bulletin, June 2026 (PDF). The S9443 revision is on page 3, under “Revised: Preventive Medicine and Screening, Professional.”
- UHC’s current preventive obligation: Preventive Care Services Medical Policy, MP.016.58 (PDF). The opening Coverage Rationale spells out the ACA preventive mandate.
- The clinical recommendation: USPSTF Recommendation: Primary Care Interventions to Support Breastfeeding (April 2025, Grade B).
Letter Writing Campaign – 4 Letters
Form letters get ignored. Five thousand identical faxes get counted as one complaint and filed. What actually moves a payer, a regulator, or a legislator is volume plus specificity: real letters, from real people, with real details from real practices and real families.
So I’ve built four templates. Each one has fill-in fields and a few “in your own words” prompts. Please use those prompts. Two honest sentences about a baby you helped, or a benefit a family is counting on, will do more than the entire rest of the letter. That’s not a figure of speech. It’s the single most effective thing you can add.
Pick the templates that fit you. Send more than one if you can.
📄 Template 1 — IBCLCs to UnitedHealthcare
The direct objection, from you to UnitedHealthcare. Put it on your own letterhead and personalize with your own story.
📄 Template 2 — To your State Department of Insurance
Two versions in one file: one for IBCLC providers, one for parents and patients. This asks the regulator to investigate whether the change violates the ACA preventive mandate and to intervene before September 1.
📄 Template 3 — To your elected officials
Two versions (provider and parent), written for both state and federal officials, with a guide inside on who to send to for what. Officials don’t set insurance policy, but they can open formal inquiries and apply pressure on the agencies that do.
📄 Template 4 — For parents, to their employer
This might be the most powerful letter of the set, and it’s for the families you serve, not for you. If a parent gets UnitedHealthcare through work, their employer is often the actual plan sponsor and can push back on UnitedHealthcare directly. Includes a formal version and a short email/Slack version.
IBCLCs: share Template 4 (and the parent versions of 2 and 3) with your clients, your support groups, your local parent networks. Families have standing and leverage that we don’t. Use it.
Where To Send These Letters
Don’t let your good intentions die on the vine. Here’s where to send your letters.
Sending to UnitedHealthcare (Template 1)
Here’s the annoying reality, and I learned it the hard way: UnitedHealthcare has no working front door for objecting to a policy. There’s no public “comment on this policy” address, and the phone-and-portal maze is a loop. The channel that actually works is certified mail to your regional Network Management office. The only catch is getting the address.
The easy way (do this first): I’ve started a thread in the Paperless Lactation Facebook group where we’re pooling regional Network Management addresses by state. Check there first. If your state’s address is already posted, skip the phone tree entirely, just mail your letter. If it isn’t, get it (see below) and post it back to the thread so the next IBCLC in your state doesn’t have to.
Getting the address yourself: Open the chat in the UnitedHealthcare Provider Portal and ask for the PO Box for your local Network Management office. Fair warning: to get through the chat you’ll have to enter a client name and payer ID. The portal will give you the address (that part worked for me). Once you have it, post it to the group thread so others in your state can skip this step.
Then: Mail your letter certified, marked Attn: Network Management. Certified mail gives you proof of delivery that can’t be quietly closed like a portal ticket. Keep your receipt and note the date.
A heads-up on what to expect (this happened to me): The published Provider Services line (877-842-3210) redirected to the portal, which did give me a PO Box for my local Network Management office and a phone number for all Network Management. A direct call to Network Management (888-362-3368) routed me to claims, handed me back the same Network Management number, and then said the call was misrouted and to try calling them again. Looks like certified mail is the best way to go.
A note on what not to do: this is a policy objection, not a claim appeal. Don’t route it through the claims-appeal fax lines, those want a member ID and a date of service and will bounce a policy letter.
Finding your State Department of Insurance (Template 2)
Every state has one (sometimes called the Division of Insurance or the Office of the Insurance Commissioner). Most have an online complaint form you can paste your letter into.
- Go to naic.org and find your state’s department, or search “[your state] file an insurance complaint.”
- Providers and parents can both file. If you’re a parent, have your UnitedHealthcare member ID handy, regulators tie consumer complaints to coverage.
One caveat: state insurance departments regulate state-regulated and ACA-marketplace plans, but many large employer plans are self-funded (ERISA), and states don’t regulate those, the federal Department of Labor does. The template works either way (the ACA preventive mandate applies to both), but if a family’s plan is self-funded, the state office may refer them to the federal level. Don’t let that stop you. The complaint still counts, and the referral itself creates a record.
Finding your elected officials (Template 3)
- Go to usa.gov/elected-officials to find your federal and state representatives by address.
- State representative, state senator, and governor → best for pushing your state insurance regulator. Use the “for state officials” bracketed language in the template.
- U.S. Representative and U.S. Senators → best for the federal angle. The ACA preventive mandate is enforced by the U.S. Departments of Labor, Health and Human Services, and the Treasury. A congressional inquiry to those agencies (or to CMS) carries real weight, and it’s the route that reaches the self-funded employer plans states can’t touch. Use the “for federal officials” bracketed language.
- Sending to several at once is good, not overkill.
For parents writing to their employer (Template 4)
- Send to HR or the benefits team (and a manager, if that’s how things move where they work).
- The letter asks HR to find out whether the plan is self-funded, the employee doesn’t need to know that in advance.
- If it’s self-funded, the employer can ask UnitedHealthcare not to apply the S9443 change to their plan. That’s leverage no individual member has.
A few things that make this work better
Personalize it. I will keep saying this because it’s the whole game. Fill in the “in your own words” prompts. Name your city. Describe one real (de-identified) case. A regulator reading their 400th letter remembers the one about the baby who wasn’t gaining weight.
Send more than one. An IBCLC can reasonably send Template 1 and Template 2 (provider version) and Template 3 (provider version). Each goes to a different decision-maker.
Bring the families in. This is the multiplier. Every parent you’ve helped is a potential sender of Templates 2, 3, and 4. Share this page with them.
Mind the clock. The change takes effect September 1, 2026. The letters all ask for action before that date. Earlier is better.
Verify before you send wide. The policy citations in these templates (MP.016.58 and the April 2025 USPSTF “B” recommendation) were accurate as of June 2, 2026. If you’re sending months from now, a quick check never hurts.
Create an advocacy page on your website. Here’s the one I created for my private practice for inspiration and copying!
Share this page
The more people who see this, the more letters get sent. Forward it, post it, send it to your local IBCLC group and your clients.
- Link: https://paperlesslactation.com/blog/fight-uhc/
- Templates were last verified: June 2, 2026
This is winnable. Payers walk back bad policy when enough people make enough noise through enough channels. Let’s be the noise.
Keep on being awesome,
Annie
Annie Frisbie, MA, IBCLC, PMH-C
Disclaimer: These templates and this page are advocacy tools, not legal advice. The policy details described here come from UnitedHealthcare’s publicly posted June 2026 Commercial Reimbursement Policy Update Bulletin. Verify current policy language before using on it.
Thank you so much for creating these templates and highlighting awareness of these changes. Unfortunately i dont think UHC will be the only insurance company making these types of moves.