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Revised December 2022
Copyright ©2022 Commission on Dietetic Registration. This handout is intended for use by the individual RDN and NDTR.
Contact CDR for questions regarding reproduction or distribution.
Question 6: Does your employer/organization, in its policies and procedures or medical staff bylaws,
rules and regulations, if applicable, recognize the RDN as qualified to perform the activity?
A RDN who works in private practice ensures there is documentation of qualifications in their
personnel file and amends any business/organizational policy or procedure to reflect added scope.
The case example provides information on what things need to be considered before beginning to
deliver health and wellness coaching services. Before performing this new activity, the RDN should also
consider the following:
• Ensure that the activity is included in job description or list of services for private practitioners,
in granted privileges if working in a hospital-associated program where privileging is required,
and in applicable policies and procedures.
• Ensure that their personnel file contains primary source verification of education, training,
credentials, if applicable, continuing education for maintenance of certification(s), and
competence in performing the activity.
• Investigate organization’s/business’s liability coverage and need for personal professional
liability insurance or additional coverage to include health and wellness coaching.
• For billable services, investigate whether this activity, as performed by a RDN, will be
reimbursed by health plan insurers, including Medicare or what service is for self-pay, e.g.,
health coaching not related to delivery of medical nutrition therapy (MNT).
o Coaching techniques can be incorporated into counseling for MNT that is reimbursed by
insurers as outlined in conditions for coverage from Medicare or private insurers.
o Health and Wellness Coaching services may be covered by some employer health plans
so client should investigate and share information with the RDN when applicable.
o The RDN is responsible for explaining the difference between counseling for MNT with
physician referral (i.e., covered by insurance), and health and wellness coaching that
may be fee-for-service (i.e., self-pay).
Disclaimer: The Case Studies are intended solely as models to assist practitioners in using the Scope of
Practice, Standards of Practice in Nutrition Care, Standards of Professional Performance, and the Scope
of Practice Decision Algorithm and suggested resources, and in determining their individual scope of
practice. They should not be viewed as determinative of any particular inquiry or outcome. The results
of an actual inquiry may differ according to the specific factual circumstances, state laws applicable to
the specific situation, and organization policies and procedures.
In this Case Study, CDR has chosen to use the term RDN to refer to both registered dietitians (RD) and
registered dietitian nutritionists (RDN) and to use the term NDTR to refer to both dietetic technician, registered
(DTR) and nutrition and dietetics technician, registered (NDTR).