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Dietitian registration and licensure in the US

 

If you want to become a dietitian in the US or if you are looking for a dietitian to work with in the US there are two things that you need to consider. One is the national registration (providing the title Registered Dietitian) and the other is state licensure.

 

This is not a complete overview of all the rules and regulations, so please see links for further information. This is meant to give you an overview of the registration, license and some issues I have seen. 

 

In order to become eligible for the title Registered Dietitian you have to attend an approved nutrition/dietetics degree as well as an approved dietetic internship. Sometimes these are combined into one. Then you must pass the Registered Dietitian exam, you can find information about that here: https://www.cdrnet.org/certifications/registered-dietitian-rd-certification.

 

Once you have passed the exam you enter your first 5 year registration cycle and to keep your registration valid you must collect continuing education points (CPE). You can find more information about this here: https://www.cdrnet.org/maintain.

 

The registration is fairly straightforward so as long as you make sure you are attending approved programs, pass the exam and so on. When it comes to state licensure it gets much more complicated. It is very important that you inform yourself about the state rules where you want to practice and that you keep up with any changes.

 

The first important fact: The state where your client is at the moment of your session is going to determine the rules. Example: if you live in Louisiana and your client is in Louisiana at the moment of your appointment, then the Louisiana state license rules apply.

If you live in Louisiana but your client is in Texas, then the Texas state license rules apply.
This is essential to understand when providing telehealth, see more information here: (https://www.eatrightpro.org/advocacy/licensure/licensure-and-telehealth). 

 

The idea of having licensure is to: “States' professional licensing laws help consumers identify who is a qualified practitioner to provide a particular set of specified services, known as the profession's scope of practice. Some individuals are not qualified for licensure because they lack the objective accredited education, experience and examination demonstrating their competency to provide services within the regulated profession's scope of practice.”

(https://www.eatrightpro.org/advocacy/licensure/professional-regulation-of-dietitians#state). 

In short, it is to protect the general public. You wouldn’t go to someone calling themselves a physician who took two weekend courses in medicine would you? 

 

Not every state has the same rules. Therefore it is very important that you check the rules in the state where you want to practice (where your client is). If you want to practice telehealth and you want to see clients in several different states, you may have to get several licenses. If the state law requires it, there is no way around it. I see many misconceptions and bad advice given in social media groups. These laws and regulations cannot be generalized. You have to check each state no matter what type of services you provide, what you call your services and yourself, and no matter if you are billing insurance or not. I have seen people stating on social media “you only need a license if you are providing MNT, or billing insurance” and similar things. It is not that simple. Please do not follow advice like this without finding out for yourself. 

 

In order to find out what the laws and regulations are in the state you are interested in you can start here: https://www.cdrnet.org/state-licensure-agency-list

 

Let’s use Louisiana as one example, only because that is where I lived and worked. You go to their licensure board website. There you can find out what is required to apply for a license, but you can also find the laws and rules. Yes, you will have to read a bit of boring and sometimes difficult to understand text. If you are unsure of the meaning of the text, contact the licensure board and ask. Never assume and don’t go asking a Facebook group for advice. This would be like googling “what is the best diet for me.”

 

On the Louisiana licensure board laws and rules under “prohibited practice” you can read the following:

“A. No person shall engage in the practice of dietetics/nutrition in the state of Louisiana unless they have a current license duly issued by the board under the provisions of Chapter 1 of these rules, unless exempted as defined in R.S. 37:3093 of the Act.”

(https://www.lbedn.org/index.cfm/rules-and-regulations)

 

Louisiana has licensure with practice exclusivity. This is the highest standard of consumer protection. There are some exemptions to this and you can go to the section written in the quoted text above to read what they are. Unless you fall under one of the exemptions, you must have a license to practice in Louisiana. 

 

As you may have seen you cannot find California on the state licensure agency list. They do not have licensure. This does not mean that they have no rules at all. If you look at the California Code, Business and Professions Code - BPC § 2585 (https://codes.findlaw.com/ca/business-and-professions-code/bpc-sect-2585.html), you will see that there are rules about title use (title protection) as well as reimbursement. So just because there is no specific license does not mean anybody can do whatever they want. 

 

Since most states have licensure or at least some laws and regulations you have to make a choice when providing telehealth via your online / virtual practice. You have to follow the state rules for where your client is. I see discussions online where some dietitians complain about the cost of applying for licensure in several states. I understand this can be an issue. However, know that there is no legal way around this. Changing your title to “coach” or calling your services “coaching” to avoid licensure because this title and services are unregulated, would be unethical as a dietitian.

(https://www.eatrightpro.org/-/media/eatrightpro-files/practice/code-of-ethics/ethicsinpractice-november2019.pdf?la=en&hash=C380331990A4E89CBC9A67C640431AA4CC2D4584

Sure, dietitians are coaches and provide coaching. However, no good dietitian would practice this way.

 

How will you as a registered dietitian define coaching vs MNT (medical nutrition therapy)? If you are coaching someone for weight loss and the person one day comes back and tells you their primary doctor diagnosed them with diabetes, what are you going to do? Are you going to ignore your patient’s medical condition that you as a registered dietitian can help with, or are you going to tell the person that you can no longer work together? Or are you going to do the right thing and either apply for a license in that state, or refer the patient to a dietitian who is already licensed there? 

 

I personally wish that there was a national license for dietitians in the US. It would make life easier for us as well as the patients. However, this is not how the US is constructed. All states have their own laws in a lot of aspects and this happens to include dietitians. You can accept it as it is or you can work on changing the laws. But you cannot break the laws because you do not like them. 

 

This does not cover everything about licensure and registration but it gives you a good start.

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