Legislative Analysis
Phone: (517) 373-8080
LICENSURE OF DIETITIAN NUTRITIONISTS
http://www.house.mi.gov/hfa
House Bill 4608 as reported from committee Analysis available at
Sponsor: Rep. Laurie Pohutsky http://www.legislature.mi.gov
Committee: Health Policy
Complete to 9-2-23
SUMMARY:
House Bill 4608 would add Part 183A (Dietetics and Nutrition) to Article 15 (Occupations) of
the Public Health Code, to establish a licensure framework for dietitian nutritionists, describe
a scope of practice, set license fees, create the Michigan Board of Dietetics and Nutrition in
the Department of Licensing and Regulatory Affairs (LARA), and require LARA to develop
and issue rules governing specified aspects of licensure.
The bill would define a dietitian nutritionist as an individual who is licensed or otherwise
authorized to engage in the practice of medical nutrition therapy under Article 15.
Practice of medical nutrition therapy would mean the provision of nutrition care
services for the treatment or management of diseases or medical conditions.
Nutrition care services would mean any part or all of the following services within a
systematic process:
• Assessing and evaluating the nutritional needs of individuals and groups and
determining resources and constraints in the practice setting, including
ordering laboratory tests to check and track nutrition status, creating dietary
plans and orders, and monitoring their effectiveness.
• Interpreting anthropometric, biochemical, clinical, and dietary data in acute
and chronic disease states and recommending or ordering nutrient needs based
on dietary data, including enteral and parenteral nutrition.
• Establishing priorities, goals, and objectives that meet nutritional needs and
that are consistent with available resources and constraints.
• Providing nutrition counseling in health and disease, including food and
nutrient counseling and counseling on food and prescription drug interactions.
• Developing, implementing, and managing nutrition care systems.
• Evaluating, making changes in, and maintaining appropriate standards of
quality in food and nutrition services.
• Ordering therapeutic diets.
Nutrition counseling would mean a supportive process, characterized by a
collaborative counselor-patient or counselor-client relationship with individuals or
groups, to establish food and nutrition priorities, goals, and individualized action plans
and general physical activity guidance that acknowledge and foster responsibility for
self-care to treat or manage an existing disease or medical condition or to promote
health and wellness.
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 Therapeutic diet would mean a diet intervention prescribed by a physician, or another
health professional licensed under Article 15, that provides food or nutrients via oral,
enteral, and parenteral routes as part of treatment of a disease or clinical condition to
modify, eliminate, decrease, or increase identified micronutrients and macronutrients
in the diet or to provide mechanically altered food when indicated.
Requirement of licensure
Beginning 18 months after the effective date of the initial rules promulgated by LARA under
the bill (see below), an individual could not engage in the practice of medical nutrition therapy
without being licensed or otherwise authorized under Article 15. In addition, only a dietitian
nutritionist could use the words, titles, or letters licensed dietitian nutritionist, dietitian
nutritionist, dietitian, dietician, nutritionist, or l.d.n. (or a combination of them), regardless of
whether they are used with qualifying words or phrases.
However, an individual, including a registered dietitian nutritionist, could use any lawfully
earned federally trademarked title and the words, titles, or letters registered dietitian, registered
dietitian nutritionist, r.d., or r.d.n.
Registered dietitian nutritionist would mean an individual who is credentialed by the
Commission on Dietetic Registration or its successor organization as a registered
dietitian or registered dietitian nutritionist.
In addition, notwithstanding the above restrictions, the following would apply:
A physician or another individual licensed under any other part or any other act could
perform activities that are considered the practice of medical nutrition therapy as long as
those activities are within their scope of practice and they do not use the protected titles
described above.
An individual could do any of the following as long as, while doing so, they do not engage
in the practice of medical nutrition therapy and do not use the protected titles described
above:
• Furnish general nonmedical nutrition information.
• Provide evaluation, guidance, information, and education on the use of food, food
materials, or dietary supplements.
• Provide explanations to individuals or groups about food or food products,
including dietary supplements.
General nonmedical nutrition information would mean information on any of the
following:
• Principles of human nutrition and food preparation.
• Principles of self-care and a healthy relationship with food.
• The essential nutrients needed by the human body and their recommended
amounts.
• The actions of nutrients in the human body.
• The effects of deficiencies or excesses of nutrients in the human body.
• Foods, herbs, and dietary supplements that are good sources of essential
nutrients in the human body.
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 An individual could provide medical weight control for prediabetes or obesity to
individuals under a program of instruction approved in writing by either of the following:
• A dietitian nutritionist.
• A health professional licensed under this Article 15 whose scope of practice
otherwise authorizes them to provide nutrition care services for the treatment or
management of the applicable disease or medical condition.
Medical weight control means the practice of medical nutrition therapy for the
purpose of reducing, maintaining, or gaining weight.
An individual could provide medical weight control services delegated under a plan of care
overseen by a health professional licensed under Article 15 whose scope of practice
otherwise authorizes them to provide and delegate nutrition care services for the treatment
or management of the applicable disease or medical condition.
Subject to provisions of the code governing the delegation of tasks, an employee or other
individual who is assisting a dietitian nutritionist and is under the dietitian nutritionist’s
appropriate supervision could perform activities or functions that are delegated by the
dietitian nutritionist, that are not discretionary, that do not require the exercise of
professional judgment for their performance, and that are within the dietitian nutritionist’s
authority to perform.
An individual could provide general nonmedical nutrition information, guidance,
encouragement, individualized nutrition recommendations for wellness or primary
prevention of chronic disease, behavior change management, coaching, assessments,
services for weight management, or other nutrition care services as long as the following
apply:
• The services do not constitute the practice of medical nutrition therapy.
• The individual does not use the protected titles described above or otherwise hold
themselves out as a dietitian nutritionist or a provider who engages in the practice
of medical nutrition therapy.
• The individual does not otherwise violate the act.
An individual who is pursuing the educational requirements for licensure as a dietitian
nutritionist could engage in the practice of medical nutrition therapy as long as all of the
following apply:
• The individual is doing so as part of a course of study.
• The individual does not engage in the unrestricted practice of medical nutrition
therapy.
• The individual is under the appropriate supervision of a qualified supervisor (see
below) who assumes full professional responsibility for the work of the individual
by verifying, directing, and authorizing the work.
• The individual is designated by a title that clearly indicates the individual’s status
as a student, trainee, or supervisee.
Unrestricted practice of medical nutrition therapy would mean the application of
dietetics and nutrition knowledge and skills by an individual who regulates and is
responsible for the individual’s own practice or treatment procedures.
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 An individual could fulfill supervised practice experience requirements for licensure as a
dietitian nutritionist as long as all of the following apply:
• The individual is engaging in the practice of medical nutrition therapy as part of a
planned, continuous supervised practice experience.
• The individual does not engage in the unrestricted practice of medical nutrition
therapy.
• The individual is appropriately supervised by a qualified supervisor who agrees to
assume full professional responsibility for the work of the individual by verifying,
directing, and authorizing the work.
• The individual is designated by a title that clearly indicates the individual’s status
as a student, trainee, or supervisee.
An individual could do either of the following:
• Provide verbal nutrition information as an operator or employee of a health food
store or business that sells health products such as dietary supplements, food, herbs,
or food materials.
• Disseminate written nutrition information in connection with the marketing and
distribution of the products described above, or discussing their use, including
explanations of their federally regulated label claims, any known drug-nutrient
interactions, their role in various diets, or suggestions as to how best use and
combine them.
Licensure
Subject to the rules promulgated under the bill, a person seeking licensure as a dietitian
nutritionist would have to meet all of the following requirements:
• The individual must hold either of the following:
o A baccalaureate, master’s, or doctoral degree from a college or university in
the United States that, at the time of graduation, was accredited in good
standing by a United States institutional accrediting body for higher education
recognized by the United States Department of Education and that is approved
by LARA. (In consultation with the Michigan Board of Dietetics and Nutrition,
LARA would have to automatically approve an academic program that is
accredited by the Accreditation Council for Education in Nutrition and
Dietetics or its successor organization.)
o An academic degree from a foreign educational institution, which degree is
validated as equivalent by a credential evaluation agency recognized by the
United States Department of Education and is approved by LARA in
consultation with the Michigan Board of Dietetics and Nutrition.
• The individual must have successfully completed a didactic program in dietetics
accredited by the Accreditation Council for Education in Nutrition and Dietetics.
• The individual must have successfully completed a planned, documented supervised
practice experience in the practice of dietetics and nutrition fulfilling the competency
requirements of a program in dietetics that is accredited by the Accreditation Council
for Education in Nutrition and Dietetics or its successor organization. The practice
experience would have to include at least 1,000 hours under the supervision of a
dietitian nutritionist or a registered dietitian nutritionist, and any supervised practice
experience undertaken after the effective date of the initial rules promulgated by LARA
under the bill would have to be under the supervision of a qualified supervisor. (In
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 consultation with the Michigan Board of Dietetics and Nutrition, LARA would have
to automatically approve an applicant’s supervised practice experience that is
accredited by the Accreditation Council for Education in Nutrition and Dietetics or its
successor organization.)
• The individual must have successfully completed the registration examination for
dietitian nutritionists administered by the Commission on Dietetic Registration or its
successor organization.
• The individual must be a registered dietitian nutritionist.
Practice of dietetics and nutrition would mean the integration and application of
scientific principles derived from the study of food, nutrition, biochemistry,
metabolism, nutrigenomics, physiology, food systems and management, and from
behavioral and social sciences in achieving and maintaining health throughout the
lifespan and in providing nutrition care services, including the practice of medical
nutrition therapy, for the prevention, management, and treatment of diseases or medical
conditions. Practice of dietetics and nutrition would not include the medical differential
diagnosis of the health status of an individual, but it would include the following:
• Nutrition assessment.
• Nutrition diagnosis.
• Nutrition support.
• Dietary and nutrition counseling and education.
• Nutrition intervention.
• Nutrition monitoring and evaluation.
• Development and administration of nutrition care standards and systems.
Nutrition assessment would mean the ongoing, dynamic, and systematic process of
obtaining, verifying, and interpreting biochemical, anthropometric, physical,
nutrigenomic, and dietary data to make decisions about the nature and cause of
nutrition-related problems and making recommendations, including recommendations
on enteral and parenteral nutrition. The collection of data would not, by itself,
constitute nutrition assessment.
Nutrition intervention would mean purposefully planned actions and nutrition
counseling intended to positively change a nutrition-related behavior, risk factor,
environmental condition, or aspect of the health status for an individual.
Nutrition monitoring and evaluation would mean identifying patient outcomes
relevant to a nutrition diagnosis and comparing the outcomes with the patient’s
previous health status, intervention goals, or reference standards to determine the
progress made in achieving desired outcomes of nutrition care and whether nutrition
intervention should be continued or revised.
Nutrition diagnosis would mean identifying and labeling nutritional problems
managed and treated by a dietitian nutritionist. Nutrition diagnosis would not include
the medical differential diagnosis of the health status of an individual.
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 Registered dietitian nutritionists
In addition to the above requirements for licensure as a dietitian nutritionist, an individual who,
on the day before the effective date of the bill, has and continues to be a registered dietitian
nutritionist in good standing would be eligible for licensure. An individual seeking licensure
under these provisions who maintains the credential conferre