Licensure and Telehealth

Can I Practice in This State?

Registered dietitian nutritionists looking to relocate, practice telehealth or otherwise practice dietetics and nutrition or provide medical nutrition therapy to individuals in another state should be aware of certain legal implications. Currently 48 states, Puerto Rico and the District of Columbia have statutory provisions regulating the dietetics profession or associated titles such as "dietitian" and "nutritionist."

Members should consider several legal implications, including:

  1. dietetics licensure and any associated practice exclusivity requirement that one be licensed to practice
  2. exemptions that may enable one to practice even without being licensed
  3. other restrictions related to telehealth, but not specific to any particular profession.

Licensure Guidance for Dietetics Practice in Emergency via Cross-Border and Telehealth Settings

To support the provision of nutrition services by RDNs during the COVID-19 national emergency, the Academy has created a listing designed to facilitate delivery of services via telehealth in multiple states. Learn more.

Licensure and Other State Professional Regulation

States typically regulate the profession of dietetics using one or both of the following provisions:

Practice Exclusivity

The statute either broadly precludes the practice of dietetics and nutrition or, more narrowly, the provision of medical nutrition therapy without a state-issued license. The 27 states, the District of Columbia and Puerto Rico, all of which regulate the practice of dietetics or MNT, are colored red on the map below, indicating that practitioners must be licensed in order to practice there — although there may be exemptions enabling practice for a short duration or for a small subset of dietetics and nutrition services. These states usually also regulate use of certain titles through a title protection provision as described below.

Note the legal status of cross-border practice is determined by the location of the client. For licensure purposes, the RDN's location is not relevant. For example, if services are provided via telehealth to a resident of Pennsylvania, then Pennsylvania law applies. If that Pennsylvania client travels across the border to see a Maryland RDN, then Maryland law applies. If the Pennsylvania client temporarily relocates to Florida, then Florida law applies.

Title Protection

The statute restricts the use of one or more specified titles, which may include "registered dietitian," "registered dietitian nutritionist," "licensed dietitian," "licensed dietitian nutritionist," "LD," "LDN," or other titles. States prohibit any public representation of one's qualifications as making them eligible to practice as a licensed dietitian nutritionist, but the statute does not restrict the actual practice of dietetics or MNT.

For purposes of employment or reimbursement, some states or employers may require verification that an individual is a licensed dietitian nutritionist. All states with licensure or certification include title protection provisions in their statutes.

In addition to the 27 states (and DC and Puerto Rico) that have practice exclusivity clauses requiring a license to practice, 21 additional states also limit the use of titles to certain qualified individuals without requiring a license to practice, and are shown in green or orange on the map below. Of these, 18 states limit the titles to licensed or certified individuals, while California, Colorado and Virginia implicitly or explicitly accept current CDR registration as adequate evidence to support use of these titles.

For additional details about the states, review the interactive licensure map.

Exemptions

Some states offer exemptions to licensure requirements under certain circumstances, including allowing:

  • Practicing for a limited, specified period of time, such as up to five days consecutively or a maximum of 30 days per year
  • Practicing under another state’s license if the requirements for licensure in the other state are substantially similar to those of the desired state
  • Practicing obesity or weight loss counseling under certain circumstances, such as helping a client follow a program developed by an RDN, physician or other qualified individual
  • Practicing solely via non-individualized group therapy sessions.

The Academy cannot provide individual legal advice; however, members are encouraged to contact their state licensing agency or board to determine any specific legal obligations. View the Academy's licensure map to find state licensure requirements and find contact information for state licensing agencies.

Telehealth Restrictions

Some states specifically restrict practice to providers who hold a state-issued telehealth certificate or other similar permissions. To verify the status of any state, RDNs should review relevant state laws collected by a trusted group, such as the Center for Connected Health Policy. To see specific relevant laws about a particular state's rules about cross-state licensing, for example, click that state, select "Cross-state Licensing" from the first drop-down menu, and click "Apply."

Note that some of these laws and regulations may only apply to physicians; that is, non-physician providers may not be required to obtain such permission. To confirm if such special permission is required, click the "Source" link under "Cross-state Licensing" to find the relevant regulation, which will identify the state agency who issues such permission. Review the state's statutory or regulatory language or confer with that state's licensure board or referenced state agency for specific questions about applicability.