Hello – below is a letter from the Academy ….also attached the three accompanying documents for RDs
Dear Affiliate Presidents, Presidents-Elect, State Regulatory Specialists, and Executive Directors,
I am excited to write to you today about a proposed rule changefrom the Centers of Medicare and Medicaid Services (CMS) that is the culmination of over two years of work between the Academy and CMS. The proposed rule
Would permit RDs to order patient diets;
Allow privileged RDs to order lab tests to monitor the effectiveness of dietary plans and orders,
Seeks comment on new strategies for provider reimbursement in rural health clinics (RHC), and
Seeks comment on other overly burdensome or redundant regulations in all facilities’ Conditions of Participation that may negatively affect dietetic practice.
For your information, we have attached the following documents; PLEASE distribute them freely to members:
Frequently Asked Questions to help members understand the details of the proposed rule and the comment period.
A sign-on letter for non-RD providers, hospitals, health systems administrators to sign in support of the provision related to RDs’ ability to order patient diets.
The Academy will be commenting on behalf of our 74,000 members and will work closely with DPGs, affiliates, and members of the CMS Workgroup in drafting our formal comments supportive of the proposed rule. As you know, the Academy regularly solicits and incorporates evidence-based opinions of DPGs and affiliates when drafting comments to federal agency notices, agency initiatives, and proposed regulations, following the process below:
Forwarding notices of regulatory initiatives upon which the Academy is considering commenting utilizing the attached template and encouraging you to share with public policy representatives or members with expertise or interest on the attached issues;
Asking DPGs and affiliates whether they will offer comments/thoughts on the regulations/notices/etc.;
Soliciting substantive answers to specific questions or issues raised by an agency’s proposed regulation;
Asking you to work within your DPG or affiliate (as you feel appropriate) to decide whether to submit substantive comments/recommendations to the Academy for incorporation in the Academy’s regulatory response;
Collecting comments from DPG and affiliate members and soliciting them on behalf of the DPG or affiliate to the Academy under the applicable timeframe. We are not seeking individual comments from members, rather a set of comments from the DPG or affiliate.
It is critical for every respondent to provide the evidence-based data with citations to support their positions to make it possible to utilize their expertise.
We are seeking comment on the exciting proposed rule change by Friday March 8th. Relevant portions of the proposed ruleare on pages 9216, 9221-9224, 9233-9235, and 9244. Specifically, the Academy is seeking input on the following issues:
The accuracy of CMS’s conservative cost-savings estimates and the assumptions underlying them;
Providing specific, documented instances of substantive harm to patients or costs to providers/hospitals (from delay, wrong orders, or other causes) resulting from existing rule’s prohibition on RDs ordering patient diets.
Mechanisms by which analogous oversight (to hospital privileging) could be ensured for RDs in long term care facilities as we work to have CMS extend the ability of RDs to order patient diets across the continuum of care;
Recommendations for revisions to additional Conditions of Participation; and
Recommendations for revising process for reimbursement for practitioners at rural health clinics.
Thank you so much for your continued involvement with these important initiatives and for offering input and expertise that allows the Academy to drive efficacious food and nutrition policy and promote the dietetics profession.
Regards, -Pepin Tuma Pepin Andrew Tuma, Esq.
Director, Regulatory Affairs Academy of Nutrition and Dietetics