How We Did It
SUMMARY OF PUBLIC TESTIMONY
105 CMR 130.000 et seq.:
HOSPITAL LICENSURE REGULATIONS
| Distribution of formula gift bags to mothers upon discharge.
The following commenters oppose the distribution of formula gift discharge bags: |
| AAP "breastfeeding policy statement recommends that health care professionals
protect, promote and support breastfeeding by actively working to eliminate hospital policies and
procedures that discourage breastfeeding such as promotion of infant formula in hospitals including
formula discharge packs and formula discount coupons". MCCAP encourages the Department to support
this policy. |
Lynda Young, MD, FAAP President, Massachusetts Chapter of the American Academy of
Pediatrics |
"Urge DPH to ban the distribution of commercial diaper bags to post-partum
patients". There is growing body of literature that suggests that breastfeeding has significant
benefits for mothers, as well as infants. AAP, ACOG, and AAFP all recommend six months of exclusive
breastfeeding. Ambiguous messages from health care providers undermine breastfeeding.
The WHO’s International Code on Marketing of Breast Milk substitutes explicitly bans promotion of
formula products through health care facilities. (Literature citations included) |
Alison M. Stuebe, MD, Boston
(Obstetrician specializing in maternal-fetal medicine, does research on the health effects of lactation
on mothers)
|
"I would like the DPH regulations to support breastfeeding in every possible
way, since formula feeding is associated with adverse health outcomes for mother and baby and excess
economic costs to families and taxpayers". Patients who receive formula gifts are likely to stick
with that brand and more likely to use bottles. "Eliminate this destructive advertising subsidy to
formula companies" |
Sylvia Fine
(Obstetrician practicing at Mt Auburn Hospital, Cambridge
|
Disallow formula companies (who are making money while the health of babies and
mothers is in jeopardy, literally) from giving out their "breastfeeding support bags".
These bags do nothing but interfere with breastfeeding.
|
Jeanette Mesite Frem, MHS, CCE, BC, CD (ALACE)
|
Discontinue the practice of offering new families discharge bags. |
Morgan Kennedy Henderson, IBCLC, Wellesley |
It is irresponsible to give ANY endorsement of a practice that is associated
with adverse health outcomes in infants and mothers. DPH should take an educated stand to protect
the health of infants and mothers, and prohibit the (distribution) of formula gift bags to
breastfeeding mothers at any time, or in any circumstances. Formula is readily available on
physician’s order if medically necessary and in stores if parents should decide to use it.
|
Lucia Jenkins, RN, IBCLC |
I oppose current practice of hospitals giving formula diaper bags to new mother.
There is research on the negative outcomes of formula feeding and it would be conflict for hospital
to market and encourage such a practice. |
Mary T Mathieu, RN |
Support for new mothers should never involve formula, except in dire
circumstances |
Kate Flook Desjardins |
Recommends changing the wording so that NO artificial baby milk or formula
product is given to ANY breastfeeding mother in Massachusetts. |
Linda Huss |
Support regulations that prohibit in-hospital marketing of formula...
eliminating the commercial diaper bags from formula companies...Would like to see...language
eliminate all forms of in-hospital marketing of formula. |
Melissa Bartick, MD |
do NOT allow hospitals to give away any free formula or formula advertising |
Colleen Humphreys |
Agree with MBC’s (Mass Breastfeeding Coalition ) official position that there is
no place for marketing of formula in hospitals, to any mother. |
Kimberly Ho, Ph.D., CCC-SLP |
Don’t think that freebies, gimmicks and the like should be given away to new
mothers in the hospital knowing that they will be more likely to stop breastfeeding. |
Constance Del Nero |
There is no place for marketing of formula in hospitals, to any mother. |
Joan Reeve |
Support restriction of commercial marketing materials to breastfeeding
mothers |
Rosalie Girard |
Indicated she thought the law was that no formula was to be given and formula
companies had to remove ANY formula from breastfeeding discharge bags. |
Estelle Grygent, RN, BS, MA |
Supports language recommended by the Massachusetts Breastfeeding Coalition |
Mary A. Foley, RN, BSN, IBCLC |
Strongly discourage the practice of marketing formula to new mothers in the
hospital. |
Andrea Adlrovandi, MSN, CNM |
Urge language be strengthened and clarified to preclude this form of commercial
advertising to vulnerable new parents. (Healthy People Goals) will not be met in Massachusetts if formula is freely distributed to breastfeeding families in the hospital and hospitals accept and freely distribute advertising incentives on behalf of commercial interests. |
Cindy Turner-Maffei, MA
and Karin Caldwell, pH, RN, FAAN, Healthy Children Project
|
Support strongest possible prohibition on the distribution of promotional diaper
bags from formula companies. |
Tanya Lieberman Northampton |
Do whatever you have to do to make the parents of our state realize their
natural right to breastfeed their babies successfully. ..if it means getting rid of all the diaper
bags and freebies handed out by the formula companies, do it. |
Kathy Abott Beverly |
Urge DPH to take stand to improve public health and stop practice of
distributing commercial discharge packs from formula companies in hospital nurseries
Evidence shows giving formula packs reduces number of women exclusively breastfeeding. Evidence that
early introduction of formula associated with adverse health outcomes. Health cost alone should be
enough to stop this practice…the financial costs of formula and increased illness
|
Susan Browne, MD Academy of Pediatrics Chapter Breastfeeding Coordinator |
Recommend change in language: "Use and distribution of commercial infant formula
marketing materials shall not be permitted. Such materials include commercial discharge gift bags
(with or without infant formula), infant formula samples, formula-feeding equipment, printed
literature or videos, and any other formula-focused gifts, infant feeding information, and
formula-company produced materials" (references included) |
Marsha Walker, RN, IBCLC Massachusetts Breastfeeding Coalition |
Endorse regulations that curtail ability of formula companies to distribute
advertising materials by way of the medical community, including diaper gift bags. |
Lise Carolyn Johnson, MD |
Stronger language needed....there is no medical or public health reason for a
hospital to dispense any free samples of a particular formula brand, even to parents who choose not
to breastfeed. (cites reasons and references) |
Kimberly G. Lee, MD,MS, IBCLC, Associate Director, Newborn Nursery, BIDMC
Marcie Richardson, MD, Assistant OB-GYN Medical Director for Clinical Quality, Harvard Vanguard
Medical Associates. Medical Co-Director, Lactation Service, BIDMC |
Discharge ‘gift bags’....are marketing, pure and simple and imply endorsement
of the health agency.. |
Mary-Jane Sackett, RN, BSN, IBCLC, RNL, CCE, CD(DONA), Pittsfield |
Practice of providing patients with commercial formula discharge bags is
appalling and should not be allowed. |
Ali Crehan Feeney Quincy |
Opposes formula in bags, suggests bags include telephone number of hospital
IBCLC and nearest LaLache League. |
Ardie Garland, CD (ALACE), CLC Cambridge |
Supports restricting the distribution of formula discharge bags to all
breastfeeding mothers. |
Madeline Boland, RN, IBCLC |
DPH need to totally restrict the distribution of formula discharge bags to all
breast feeding mothers |
Nancy Aberdale, RN, BSN, IBCLC, Coordinator, Lactation Services, Baystate Medical
Center
Linda Cauley, RN BSN< IBCLC
|
DPH need to totally restrict the distribution of formula discharge bags to all
breast feeding mothers |
Shirley Hamill, RN, BSN, IBCLC, Coordinator Lactation Services, Baystate Medical
Center |
Supports proposal to change and strengthen the regulation restricting the
distribution of discharge gift bags even with the formula removed from bags. Supports elimination
of marketing as key to the Baby-Friendly hospital initiative. |
Janet T. Leigh, MS, RN |
Supports restriction on distribution of formula company discharge bags..
marketing ploy. .disservice to poor women as they discourage feeding human milk—the best nutrition
for their babies. Distribution undermines breastfeeding duration and exclusivity.
Boston Medical Center creates its own diaper bag gift containing patient care items, diapers, breast
pads, water bottle, nail clippers and coupons. ..bags paid for by nursing department.
|
Breastfeeding Center at Boston Medical Center (Lindsay MacAuley, BA, Anne Merewood,
MA, IBCLC, Barbara L. Philipp, MD, FAAP, FABM, Aixa Gonzalaez, RN, IBCLC, Esther Gerendas, PNP,
IBCLC, Michele Brady, RN, Robin Humphreys, RN, IBCLC, Karina Yong, RN, IBCLC, Susan Davies, CPA,
LuAnn Sweeney, RN, Doris Burford, RN, IBCLC, Amy Newbery, Michelle Phillips, Luz Lopez,
Patricia Francisco |
Supports restriction on distribution of discharge bags by formula companies |
Charlotte Conway, BSN, RN, IBCLC, Sarah Massey, BSN, RN, IBCLC, Kate Shore, RNC,
BSN, MSN, IBCLC (Lactation Consultants of postpartum floors of Beth Israel Deaconess Medical
Center |
Having formulas companies directly involved in how babies are fed either directly
through donations or indirectly through gifts is not in the best interests of our citizens. |
Barbara Popper, M.Ed., IBCLC Needham |
Supports removal of all commercial formula discharge bags from hospitals |
Mary Jeanne Hickey Weymouth |
Urge you to ban the distribution of free diaper bags and/or formula to new m
others in the hospital. |
Barbara J.Graczyk, RN,BSN,IBCLC Stoneham |
Supports inclusion of strong language that discourages hospitals from marketing
the use of formula and thereby undermining the efforts of physicians, nurses and other health care
providers to make breastfeeding the preferred method of feeding newborns. |
Massachusetts Medical Society |
The following commenters support the distribution of
formula discharge gift bags as outlined in current regulations:
|
| ICF believes that the choice to receive an infant formula sample should be
decision between the health care professional and the parent.
Prohibiting or restricting health care professionals from discussing feeding options and providing
formula samples and information, if needed or requested, will impede a health professional’s primary
goal, namely to ensure the health and well-being of their patient...does not believe prohibiting or
restricting the distribution of formula samples will increase either the initiation or duration of
breastfeeding. |
Mardi K. Mountford, MPH, Executive Director, International Formula Council |
Recommends eliminate restriction since it does not respect or acknowledge
patient’s right to choices. Rely on (magazines, gift packs, brochures etc. for parental education
through discharge) If this in fact is going to remain in the regulations be advised that we
consider this to have been included by a special interest group and that it takes away hospital
decision making and patient choice. |
Northeast Perinatal Team |
Proposed regulation an unnecessary intrusion of regulations into medical
practice and into the physician patient relationship. |
John M. Fiascone, MD NICU Director, Tufts-New England Medical Center |
Opposes amendment that would prohibit the distribution of infant formula samples
to mothers or any information with the manufacturer’s name… misguided and imposes unnecessary
regulatory burden without any real health benefit.
In order to affect breastfeeding rates, efforts must be undertaken to improve education and support
for breastfeeding. In some instances, medical experts suggest the use of infant formula is entirely
appropriate. |
Susan M. Connelly Senior Manager, State Affairs Grocery Manufacturers
Association |
Receiving the formula pack from the hospital did not deter my decision
(to breastfeed) actually it reinforced it....wealth of information in the formula pack. |
Lisa Duddy |
The bag I received at the hospital, under the direction of my pediatrician
assisted the success of my breastfeeding….contained very useful and pertinent information that aided
me the first week home when lactation support was not available. Supplement of formula helped
correct son’s jaundice more quickly. |
Carolyn McCabe |
Urge Department to maintain language as previously written and do not make the
proposed revisions related to prohibiting any use of commercial products. 1) Community hospitals
may need the opportunity to use commercial products in the purchase of products or supplies to offset
the high cost of purchasing many routine goods and items. (hospital already required to meet strict
OIG, Anti-Kickback and FTC gifts and advertising prohibitions ( 2) Should hospital have a contract
or agreement with a commercial company, under the Contracts Clause of the US constitution, a
government agency is barred from impeding that contract. (3) Department should not be regulating
commercial endeavors as long as consistent with hospital operations and not related to harming health
or safety of a patient.. |
Anuj K. Goel, Esq., Director, Regulatory Compliance, Massachusetts Hospital
Association |
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