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Registered Dietitians Now Can Write Diet Orders for Patients in Pennsylvania Hospitals

September 24, 2015

The Pennsylvania Department of Health (DOH) is set to begin implementation of a Centers for Medicare & Medicaid Services (CMS) rule allowing registered dietitians to write diet orders for hospitalized patients if approved by the facility medical staff.

The regulation allows registered dietitians to fully function within their scope of practice and expertise while preserving the ultimate authority of the physician in the care of the patient.

HAP, the Pennsylvania Department of Health, the Pennsylvania Academy of Nutrition and Dietetics, the Pennsylvania Medical Society, and the Pennsylvania Board of Nursing have worked to align the CMS regulations with state regulations governing licensed dietitians to allow for implementation of this rule in the commonwealth.

In order to implement the rule in Pennsylvania, hospitals must apply for an exception for the regulation regarding medical orders (107.61 Written Orders) from DOH.

DOH granted the first exception during July 2015 under the following conditions:

  • A physician member of the medical staff will have ultimate responsibility for the patient’s care
  • A physician member must first order the patient’s diet; then delegate dietary orders to a registered dietitian who can under this delegation alter, modify, or change the physician’s original order; and specifically note in the medical record the delegation to the dietician to alter, modify, or change the original order
  • A registered dietitian issuing an order for a patient’s diet must act under the direction or supervision of a physician member of the medical staff
  • The medical staff bylaws outline the rules and regulations, qualifications, status, clinical duties, and responsibilities of registered dietitians
  • The medical staff bylaws delineate the responsibilities of the physician members of the medical staff in relation to registered dietitians
  • The registered dietitian issuing an order for a patient’s diet must act in accordance with the medical staff bylaws and any rules and regulations, policies and procedures, or hospital bylaws that are incorporated by reference in the medical staff bylaws

Significant cost savings are anticipated and documented by CMS for allowing registered dietitians to write diet orders.

Questions about the rule or applying for the exception may be addressed to Mary Marshall, HAP’s director for workforce and professional development.

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