A Professional’s Guide to Practicing Nutrition in Missouri
What is scope of practice for providing nutrition services in the state of Missouri? This is a very popular topic at the MNA. Answering this question is essentially how the MNA was formed.
Missouri, was an Exclusive Scope of Practice state until August of 2021.
The MNA worked tirelessly from 2018-2021 advocating for this change in order to provide nutrition professionals in Missouri the right to use their training. This too would mean Missourians would have more options and access to food education. In May of 2021, the Missouri General Assembly voted in favor to amend the Dietitics Practice Act. In August of 2021 the amendment to update this law went into effect changing Missouri from what is referred to as a restrictive state, “red state”, or Exclusive Scope of Practice State to a “Title Protection State”.
Thanks to the dedication of Missouri Nutrition Alliance members and the dedication from the National Association of Nutrition Professionals to see this law change, holistic nutrition professionals may now work with clients to provide individualized advice, counseling, and evaluations concerning food, diet, or nutrition.
Prior to this change anyone who was not a Registered Dietitian was legally prohibited to provide anything more than “generalized nutrition information”. Counseling and evaluating client needs was also prohibitive. To commit any of this acts was a Class A Misdemeanor, punishable by up to a $2000 fine and up to one year in jail.
It is still prohibitive for a person working in the field of nutrition to use a title or set of credentials that has not been granted or earned through professional training.
In this updated law, a new stipulation requires that holistic nutrition professionals provide a full disclosure document to their clients before working with them. The information must include:
The person’s name and title;
The person’s business address and telephone number;
A statement that the person is not a dietitian licensed by the state of Missouri;
A statement that the information provided or advice given may be considered alternative care by licensed practitioners in the state of Missouri; and
The person’s qualifications for providing such information or advice, including educational background, training, and experience”.
In Missouri, one must be licensed by the state in order to provide medical nutrition therapy services. The only way to obtain licensure is to be a registered dietician or a medical provider with medical nutrition therapy listed within the scope of practice for that license. If you are not a registered dietitian the exemption language under the new law will apply to you.
The Dietetics Practice Act of Missouri
“2021 Reviser: EXEMPTIONS:
Sections 324.200 to 324.225 “Dietitian Practice Act.”
324.206.
As long as the person involved does not represent or hold himself or herself out as a dietitian as defined by subdivision (4) of subsection 2 of section 324.200, nothing in sections 324.200 to 324.225 is intended to limit, preclude, or otherwise interfere with:
Self-care by a person or gratuitous care by a friend or family member;
Persons in the military services or working in federal facilities from performing any activities described in sections 324.200 to 324.225 during the course of their assigned duties in the military service or a federal facility;
A licensed health care provider performing any activities described in sections 324.200 to 324.225 that are within the scope of practice of the licensee;
A person pursuing an approved educational program leading to a degree or certificate in dietetics at an accredited or approved educational program as long as such person does not provide dietetic services outside the educational program. Such person shall be designated by a title that clearly indicates the person’s status as a student;
Individuals who do not hold themselves out as dietitians marketing or distributing food products including dietary supplements as defined by the Food and Drug Administration or engaging in the explanation and education of customers regarding the use of such products;
Any person furnishing general nutrition information as to the use of food, food materials, or dietary supplements, nor prevent in any way the free dissemination of literature;
A person credentialed in the field of nutrition from providing advice, counseling, or evaluations in matters of food, diet, or nutrition to the extent such acts are within the scope of practice listed by the credentialing body and do not constitute medical nutrition therapy; provided, however, no such individual may call himself or herself a dietitian unless he or she is licensed under this chapter.
A credentialed person not representing or holding himself or herself out as a dietitian, who performs any of the acts or services listed in subsection 1 of this section, shall provide, prior to performing such act or service for another, the following:
The person’s name and title;
The person’s business address and telephone number;
A statement that the person is not a dietitian licensed by the state of Missouri;
A statement that the information provided or advice given may be considered alternative care by licensed practitioners in the state of Missouri; and
The person’s qualifications for providing such information or advice, including educational background, training, and experience.”
Health Coaches
Health coaches are defined as philosophical in scope. A health coach who knows her/his scope of practice leads by example, instills ideas and “coaches” a client to make lifestyle changes in a client led setting, rather than making individualized recommendations about diet and supplementation.
There are many health coaches who are qualified to do much more than what was just described. However, even outside the confines of the law, in the nutrition sector, client led goal setting and generalized information is specifically what health coaches are technically trained to do.
The more you know, the more professional you must be.
Non licensed practitioners do not diagnose, treat, or cure disease regardless of their training.
Many nutrition professionals in the unlicensed nutrition sector are extensively trained to assess and customize dietary needs for individuals. However, it is a common misconception for students to assume when entering a training program that borders on medical nutrition therapy, that they will be able to use their skill set for compensation once their training is completed. Prudence is advised.
Many of the more popular nutrition training programs are offered by national associations and universities. Education on individualized state laws isn’t included in these curriculums. Knowing the definition of medical nutrition therapy as defined by institutions that use this term to code for insurance reimbursement is the best way to understand how to stay in your lane.
Nutrition professionals
In many cases nutrition professionals have significantly more training on food therapy and micronutrients than the average doctor, nurse or other licensed providers with “nutrition” listed in their scope of practice. Because of this nutritional professionals have an even greater responsibility than health coaches do to be careful when making claims, suggestions, and recommendations regarding their training.
A non-licensed practitioner interpreting lab-work for compensation “can” be interpreted by another licensed provider as outside of scope of practice. It is important to note that up until this law went into effect, it was legally prohibitive for a non licensed provider to do so.
A nutrition professional with this type of training is advised to use this skill set while working with a licensed provider. This skill can be used to better support a client, not to make specific determinations directed to the client that could be interpreted as medical nutrition therapy, diagnosing, treating, or curing a disease.
The ideal setting for nutrition professionals in a previously restrictive state is to utilize their skills in partnership with licensed providers who trust the nutrition professional’s training. Licensed providers who do not have specific nutrition training and who respect scope of practice, prefer to refer to someone who has this specialty.
The Place for the Non-Licensed Professional
Understanding scope of practice legally but also within one’s own professional designation is essential to being recognized as a true professional. By law, in Missouri, your scope of practice in this field is defined by your scope of training. Medical nutrition therapy is still out of scope.
It is paramount that we all understand that working outside of our scope puts into question the integrity of the entire industry/sector to which we represent. Legitimizing our profession is the primary goal of the MNA. If we can’t earn the respect from our communities, we will never be able to help those whom we wish to serve.
The MNA knows that confident practitioners are the ones who thrive the most professionally, regardless of their type of training.
Missouri nutrition professionals can ensure a stronger foothold in the health and wellness sector by joining the MNA.
We actively seek and advocate for more inclusive legislation to practice.
We protect Missouri professionals legally by educating them on how to stay in their professional lane.
We educate the public about our sector, while increasing our professional member’s visibility through community outreach projects.