Academy Advocates for the Profession in Comments to HHS

02/06/2020 - Responding to the U.S. Department of Health and Human Services’ request for feedback for improving Medicare by eliminating unnecessary or overly burdensome regulations (as directed in Executive Order 13890), the Academy urged HHS and the Centers for Medicare & Medicaid Services to make changes to various specified laws and regulations that prevent Medicare beneficiaries from getting the critical and effective care they need from RDNs without unnecessary and expensive delays, including rules that prevent RDNs from independently providing and billing consistently across settings and benefit types. 

In addition, in the comment letter sent last week, the Academy recommended “that all alternate payments models and all policies aimed to address care of Medicare beneficiaries with nutrition-related chronic diseases in any care setting should routinely require inclusion of RDNs as part of the care team (including virtual teams, meaning RDNs should not have to be directly in a Patient Centered Medical Home building to be a part of the team and help the patients manage their chronic conditions). Payment models should provide funding for the nutrition services provided by the RDN, either through enhanced fee for service, enhanced Per Member Per Month fees, part of a bundled payment for chronic conditions and/or episodes of care, as well as access to shared savings and incentive programs.”  By eliminating CMS regulations that require more stringent supervision than existing dietetics state scope of practice laws, or that limit registered dietitian nutritionists from practicing at the top of our license, or by “integrat[ing] qualified and effective providers, such as RDNs, into all payment and delivery models[, CMS can ensure] beneficiaries have the ability access the right care, at the right time, from the right provider.