Deciphering State Licensure Rules for Telehealth

By Courtney Lee, MS, RDN, CLT, CFCS

Telehealth and state licensure….what a topic. Everywhere you find dietitians in private practice, you will also find many differing opinions on and interpretations of the rules. It seems that every dietitian entering into private practice asks the question, “Do I need to be licensed if I am providing a virtual service?” The answer can vary by state, type of service you provide, other professionals you work with, and interpretation of the laws. While dietitians can also serve as health coaches and “nutritionists,” first and foremost, dietitians are licensed healthcare providers. This is a key distinction when interpreting the rules.

Below is a list of questions to help determine if and where you need to be licensed:

Am I providing telehealth? If you have a virtual practice, see clients virtually, or have consults through phone calls, you are providing telehealth.

Am I providing medical nutrition therapy (MNT)? It’s nearly impossible to separate knowledge about nutrition and disease from recommendations given to clients. Certainly dietitians can focus on general wellness, but that doesn’t mean they never provide MNT. If the answer is yes, you need to be licensed. In addition, know that providing MNT under a non-dietitian title (e.g., health coach) to avoid applying for licensure violates the Academy’s Code of Ethics for dietitians.

Where are your clients? Telehealth defines the place of business as the location (state) of the client or patient, not by your location.

What are the state licensure requirements where you are and where your clients are (if different)? You need to know the requirements for every state in which you have clients. If your state or any state where you have clients requires licensure, you need to be licensed in each of those states.

If your (or your clients’) state doesn’t require licensure, does anyone else? If you accept insurance or have a partnership with other providers, you may need to be licensed even if your state doesn’t require it.

If you were offering this service in person, would you need a license? If the answer is yes, then you need a license to offer it via telehealth as well.

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State licensure processes vary by state, take time to process, and can become expensive when you have to maintain more than one. However, licensure protects the public from unknowingly receiving nutrition counseling from unqualified people and prevents dietitians from being confused with these unqualified people. Don’t let the process of securing a state license prevent you from doing the work and providing your services across state lines. You’re a healthcare provider. Take care of your licensure needs so you can maximize your career potential.

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Courtney Lee MS, RDN, CLT, CFCS has a virtual private practice specializing in personalized nutrition & anti-inflammatory diets. She loves helping people use nutrition to change their lives and enjoys empowering other RDNs to do the same!

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