Academy Advocates for Sustainable Billing Practices for Medical Nutrition Therapy

The Academy of Nutrition and Dietetics underscored the critical importance of sustainable billing practices for Part B Medical Nutrition Therapy (MNT) in hospital outpatient departments (HOPDs). In a comment letter submitted to the Centers for Medicare & Medicaid Services (CMS), the Academy acknowledged the many challenges facility-based providers face in submitting claims for MNT when the service is delivered by registered dietitians from an outpatient facility-based location.

Medical nutrition therapy provided by a registered dietitian nutritionist is a vital health care service, offering essential support to patients in managing various health conditions. Despite its significance, the lack of clarity in billing procedures for MNT in HOPDs has resulted in adverse outcomes including the capping of services, insufficient staffing and restrictions on provider access, all of which negatively impact beneficiary access to evidenced-based nutrition care.

While MNT is an independent service paid for under the Medicare Physician Fee Schedule, there is a misconception in the facility-based HOPD that MNT falls under “outpatient therapy services” and therefore is not a standalone service. Since the outset of the COVID-19 Public Health Emergency in 2020, regulations regarding the delivery of MNT from various settings have evolved significantly, particularly MNT provided via telehealth.

With these flexibilities set to expire at the end of 2024, the Academy emphasized the urgent need for clarity and streamlined billing practices to ensure uninterrupted access to MNT services continues in 2025 and beyond. By addressing these challenges, health care providers can better meet the growing demand for medical nutrition therapy while ensuring the sustainability of services within hospital outpatient departments.

Read the Academy’s letter to CMS.