Why do we need licensure of RDNs and other advanced-degree nutritionists?

• In order to protect public health and safety, Medical Nutrition Therapy and other complex nutrition care services should only be provided by qualified individuals with the education, training and experience necessary to ensure safe and effective care.

• With numerous and often-changing sources of nutrition advice and opinions purporting to be able to treat a wide variety of ailments, it can be very challenging for individuals with particular diseases or conditions to determine who they can turn to or who they can rely on for competent, safe, and appropriate advice that will not result in worsening health, diminished quality of life or increased health care costs. 

• Licensure enables Michigan consumers to easily identify those individuals Michigan recognizes as qualified providers of nutrition care services and whether an individual is eligible to provide Medical Nutrition Therapy.

• Allows for collaboration with other licensed health professionals (SLPs, exercise physiologists, etc.) to further strengthen and protect public health.

Will this licensure law monopolize the industry or hamper the ability for non-licensed nutrition practitioners? Will licensure stifle freedom of choice for consumers seeking nutrition advice?

• No.  This licensure legislation continues to allow the public to seek nutrition advice from whomever they want.

• Any individual or group/business can continue to provide individual guidance, wellness services, counseling on general healthy eating, or nutrition information obtained from research, educational, corporate, or government sources without needing to be licensed.

• The goal of this legislation is not to stop individuals from providing nutrition care; it is to protect the public from unsafe medical nutrition therapy.

• The proposed legislation merely establishes the minimum education and experience requirements for those nutrition professionals qualified to treat or manage diseases or medical conditions.

• Only Michigan and Arizona fail to regulate the provision of Medical Nutrition Therapy or the qualifications and/or titles of those providing it. Moreover, most states require providers of Medical Nutrition to be licensed because legislatures found “the practice of dietetics and nutrition or nutrition counseling by unskilled and incompetent practitioners presents a danger to the public health and safety.” Dietetics and Nutrition Practice Act – Section 468.502 (Florida).

Why choose a licensed nutrition professional instead of another individual providing nutrition services?

• All complex and potentially harmful nutrition care services, including any services provided to individuals with medical conditions or diseases, such as diabetes, heart disease, cancer, gastrointestinal diseases, and kidney diseases.

• Incompetent or unskilled practitioners have been shown to cause significant harm, delay effective and safe intervention, decrease quality of life and increase health care costs.

• An advanced degree alone provides no assurance that the academic degree holder has demonstrated an ability to translate knowledge into practice or meets the necessary competencies. To meet established standards of practice, an academic must undertake specialized training, complete supervised practice experiences and obtain an accredited evaluation of their competency. 

• Michigan’s proposed law to license dietitian nutritionists adopts this national standard for programmatically accredited education, training, and experience.

Will licensure impact gym employees, health coaches, holistic nutrition practitioners, and others and their ability to practice?

• No. These individuals can continue to provide information related to athletic training, coaching and holistic nutrition for a healthy diet. For individuals in these occupations to be impacted by this licensure bill, they would have to be treating or managing diseases or medical conditions, which would violate their practice acts.

• Knowledge about fitness and exercise do not equate with knowledge about nutrition and dietetics, let alone confer an ability to counsel patients with malnutrition or end-stage renal disease about their nutrient disease (i.e., provide. Medical Nutrition Therapy). Similarly, a state license recognizing one’s ability to provide complex nutrition care services such as Medical Nutrition Therapy confer neither authority nor ability to provide advice regarding exercise and fitness.

• Professionals and lay practitioners who work with the public should recognize their areas of expertise and, when an individual’s needs exceed their expertise, refer them to other professionals with competency in the areas needed.

• Qualified health professionals in Michigan, including, MDs, PA, NPs, RNs, OTs, PTs, SLPs, chiropractic, naturopathic and other professionals operate competently in their fields and know when to refer someone to a more specialized practitioner.

What does MNT involve that cannot be provided by someone who does not meet the criteria for licensure but has a lot of experience?

• Medical Nutrition Therapy is evidenced-based and includes a comprehensive nutrition assessment, nutrition diagnosis, individualized interventions, and ongoing evaluation and monitoring to improve health outcomes including delaying the advancement or preventing the worsening of a disease.

• RDNs meet rigorous scientific standards in their education, training, and experience in disease management.

• An individual who has obtained a few days or months of generalized health training is not qualified to apply complex Medical Nutrition Therapy. The depth and scope are key indicators of who is and is not qualified.

• The Center for Medicare and Medicaid Services (CMS) has ruled that: “RD[N]s are the professionals who are best qualified to assess a patient’s nutritional status and to design and implement a nutritional treatment plan in consultation with the patient’s interdisciplinary care team. In order for patients to receive timely nutritional care, the RD[N] must be viewed as an integral member of the hospital inter-disciplinary care team, one who, as the team’s clinical nutrition expert, is responsible for a patient’s nutritional diagnosis and treatment in light of the patient’s medical diagnosis.”

• The National Academies of Science, Engineering and Medicine (formerly the Institute of Medicine) recognizes that “the registered dietitian [nutritionist] is currently the single identifiable group of health-care professionals with standardized education, clinical training, continuing education and national credentialing requirements necessary to be directly reimbursed as a provider of nutrition therapy.”

What is the difference between a Registered Dietitian Nutritionist and a Nutritionist?

• Based on their professional education and training standards, every RDN is a Nutritionist but not every Nutritionist is an RDN.

• RDNs work in a variety of settings. In health care, their title may be Clinical Dietitian. In school food service, corporate dining/wellness, the food industry, or health and wellness centers it may be Nutritionist.

• The RDN credential is a trademark of the Academy of Nutrition and Dietetics and is the only nutrition credential that requires education and supervised practice to be programmatically accredited by an accrediting body recognized by the U.S. Department of Education for this purpose.

• The term Nutritionist is not trademarked and may be used by anyone who wishes to use it. 

What impact will this bill have on our state economy, jobs and the way you currently practice in Michigan?

• No negative impact is anticipated.  Unlicensed nutrition service providers continue to have the ability to offer general nutrition advice in a variety of settings and can offer nutrition counseling and individualized guidance to healthy clients.

• RDNs in Michigan will likely notice little change in the way they currently practice; however, licensure enables licensees to practice at the height of their scope of practice and opens professional opportunities resulting from health care stakeholders’ recognition of the value of highly qualified nutrition professionals.

• Michigan has 22 accredited academic and experiential programs providing the highest quality education and training for dietetic students and interns.  Licensure will enable licensees to order therapeutic diets, practice telehealth with reciprocity in other states across the country, and open opportunities for third-party reimbursement conditioned on having a state license, all of which are expected to lead more graduates of these programs to choose Michigan to live, work, and build their families. 

• Licensure will increase access to Medical Nutrition Therapy for Michigan citizens since most insurers require a licensed professional to provide those services. 

• Hospitals, clinics and physician offices currently providing Medical Nutrition Therapy by RDNs would also be able to receive reimbursement for these services. 

• Increased accessibility to Medical Nutrition Therapy will improve health and reduce health care costs.
  • Currently heart disease is the leading cause of death in Michigan (MI Department of Health and Human Services).
  • Twelve percent of Michigan residents are living with diabetes, while another 37% have prediabetes and may be unaware (American Diabetes Association). Diagnosed diabetes costs an estimated $9.7 billion in Michigan each year (American Diabetes Association).
  • Michigan’s adult obesity rate is 32%, up from 22% in 2000 (Center for Disease Control; State of Obesity). The cost of obesity to Michigan is over $58 billion annually (Obesity Care Advocacy Network).

• Licensure will facilitate working across state lines whether through consulting, corporate positions, telehealth or with health systems with facilities in more than one state.

How many dietitians are in MI?

• Over 4,000 Registered Dietitian Nutritionists in Michigan would qualify to be LDNs under this legislation.

How many states have licensure?

• Forty-eight (48) states plus the District of Columbia and Puerto Rico have some type of regulation – licensure, certification, or title protection. 

• Michigan and Arizona are the only two states that have no regulation at all for practicing Medical Nutrition Therapy.

What are good examples of Medical Nutrition Therapy to share with legislators to demonstrate the complexity of the care being provided?

• COVID/RDN handout
• Stunt Man Needs MNT video
• Michigan Dietitian Tells Surprising MNT Story video
• Hero to a Military Mom video
• Michigan Dietitian Saves Kidneys video
• But feel free to share one of your stories!