Academy Comments to CDC re ICD-10-CM Codes for Food Insecurity

May 10, 2019

Donna Pickett, MPH, RHIA
Co-Chair, ICD-9-CM Coordination and Maintenance Committee
3311 Toledo Road
Hyattsville, Maryland 20782
Sent via Email to

Re: Proposed New Diagnoses Codes and Revisions, Including Food Insecurity

The Academy of Nutrition and Dietetics (the "Academy") strongly supports the request submitted by Blue Cross Blue Shield of Vermont and the Yale School of Nursing for new ICD-10-CM codes related to food insecurity. Representing over 107,000 registered dietitian nutritionists (RDNs);1 nutrition and dietetic technicians, registered (NDTRs); and advanced-degree nutritionists, the Academy is the largest association of nutrition and dietetics practitioners and is committed to a world where all people thrive through the transformative power of food and nutrition.

It is the position of the Academy of Nutrition and Dietetics that systematic and sustained action is needed to achieve food and nutrition security in the United States, where millions of infants, children, and adults regularly experience the limited or uncertain availability of nutritionally adequate and safe foods.2 As noted in the Academy's position paper on food insecurity,

To achieve food security, effective interventions are needed, along with adequate funding for, and increased utilization of, food and nutrition assistance programs; inclusion of nutrition education in such programs; strategies to support individual and household economic stability; and research to measure impact on food insecurity- and health-related outcomes. . . . Negative nutritional and non-nutritional outcomes are associated with food insecurity across the lifespan, including substandard academic achievement, inadequate intake of key nutrients, increased risk for chronic disease, inferior disease outcomes, and poor psychological and cognitive functioning.3

Although it may seem that new codes would add unnecessary complexity, the truth is adding a specific Z59 code for food insecurity to the ICD-10-CM code set would facilitate the storage and retrieval of diagnostic information for clinical, epidemiological, and quality purposes. It would support data collection and research to better understand the incidence, treatment, and morbidity/mortality associated with food insecurity. It would also aid in tracking progress toward meeting national health goals (e.g., Healthy People 2020) related to food security. Finally, because food insecurity and water insufficiency can occur simultaneously and independently and necessitate different interventions, it makes sense to separate the two issues for identification, tracking, and treatment purposes.

The Academy supports a sustained shift in health care delivery to prioritize population and preventive health care. Specific language for food insecurity would provide a much needed opportunity to integrate food security strategies into the broader health care movement to address social determinants of health. Helping individuals avoid food insecurity or addressing it earlier in its cycle (which could be accomplished with suggested and clarified code Z59.41 Lack of adequate nourishing food) would permit more cost-effective approaches to disease prevention and treatment given the association of food insecurity with an increased risk for malnutrition, poor health, and chronic disease. These proposed revisions to the ICD-10-CM would support screening and measurement of food security status in all settings, referral (and tracking of such referrals) to appropriate health care and community-based resources, communication of food insecurity information to stakeholders, and provision of appropriate nutrition care by RDNs.

Thank you for the opportunity to provide the Academy's comments in support of the request submitted by Blue Cross Blue Shield of Vermont and the Yale School of Nursing for new ICD-10-CM codes related to food insecurity. We see their approval as an important and necessary step forward in understanding and addressing this key social determinant of health. Please do not hesitate to contact Jeanne Blankenship by phone at 312/899-1730 or by email at or Marsha Schofield at 312/899-1762 or by email at with any questions or requests for additional information.


Jeanne Blankenship, MS, RDN
Vice President, Policy Initiatives & Advocacy
Academy of Nutrition and Dietetics

Marsha Schofield, MS, RD, LD, FAND
Senior Director, Governance
Academy of Nutrition and Dietetics

Ben Atkinson, MS, RDN, CD
Chairman, 2018-2019
Interoperability and Standards Committee
Academy of Nutrition and Dietetics

Lois Hill, MS, RD, LD, LDE
Policy & Advocacy Leader
Renal Dietitians Practice Group
Academy of Nutrition and Dietetics

1 The Academy has approved the optional use of the credential "registered dietitian nutritionist (RDN)" by "registered dietitians (RDs)" to more accurately convey who they are and what they do as the nation's food and nutrition experts. The RD and RDN credentials have identical meanings and legal trademark definitions.

2 Holben, D. H., & Marshall, M. B. (2017). Position of the academy of nutrition and dietetics: Food insecurity in the united states. Journal of the Academy of Nutrition and Dietetics, 117, 1991-2002. doi:10.1016/j.jand.2017.09.027.

3 Ibid