Providing MNT Services During the COVID-19 Public Health Emergency

03/16/2020 - The Academy supports access to medical nutrition therapy services for all citizens during the current public health emergency. The Academy recognizes the potential financial impact of the COVID-19 pandemic for members across practice settings where MNT services are provided.

  • Read the letter from the Academy to the U.S. Department of Health and Human Services Secretary Alex Azar urging Medicare beneficiaries be granted access via telehealth.

Many Academy members have inquired about the ability to bill public and private payers for MNT services delivered via telehealth. While many answers continue to be unknown, here is what we know as of today:


Congress passed the Coronavirus Preparedness and Response Supplemental Appropriations Act which was signed by the President and became law on March 6, 2020. This legislation allows physicians and other health care professionals to bill Medicare fee-for-service for patient care delivered by telehealth during the current coronavirus public health emergency. This law gives the U.S. Department of Health and Human Services Secretary the authority to waive or modify certain telehealth Medicare requirements, such as the originating site requirement.

The legislation also allows telehealth services to be provided to Medicare beneficiaries by phone, but only if the phone allows for audio-video interaction between the Medicare provider and the beneficiary. This expansion is limited to qualified providers who have furnished Medicare services to the individual in the three years prior to the telehealth services.

At this time, the Centers for Medicare & Medicaid Services has not released guidance on how they will be implementing these provisions. However, it appears registered dietitian nutritionists who are Medicare providers may be able to deliver MNT services to their current Medicare clients with the beneficiary located in their home.

RDNs also continue to have access the new G codes (G2061, G2062, G2063) covered by Medicare as of January 1, 2020 for online digital evaluation and assessment services, which are not restricted by originating site and other Medicare telehealth regulations. Once again, these G codes are for use with established Medicare clients. Health care providers must still comply with state telehealth laws and regulations

Private/Commercial Payers

What is happening in the private health insurance section remains unclear and may vary from payer to payer and product. Individual health insurance companies are beginning to release guidance to their provider networks regarding updates to their telehealth policies; once again details of these policies and what they mean for MNT services provided by RDNs remains unclear.

The private insurance market is regulated at the state level, and coverage and payment policies fall under state jurisdiction. The Academy recognizes that members are looking for specific guidance and until payers provide such guidance, the Academy is limited in our ability to answer questions.

The Academy advises members to read all provider updates published by the specific insurance companies with whom you are currently under contract. Contact your provider relations representatives with your questions. Continue to verify benefits prior to rendering services and use HIPAA-compliant platforms for the delivery of services via telehealth.

Coverage, payment and other aspects of getting paid for services during this public health emergency are continuously evolving. The Academy will keep members informed of new developments as they relate to the provision of MNT services as they become available.

Learn more about telehealth services and the new G codes and CPT codes for online services in the November issue of the MNT Provider newsletter.