The Centers for Medicare and Medicaid Services acknowledged the substantial feedback from the Academy, registered dietitian nutritionists and stakeholders regarding the proposed removal of malnutrition and "at risk for malnutrition" from the Non-Therapy Ancillary (NTA) comorbidities list in a recent Request for Information located within the CY25 Skilled Nursing Facility Proposed Rule. The final rule noted that the agency will consider the comments in future rulemaking.
The Academy submitted comments to the draft rule that underscored the critical repercussions of untreated malnutrition, which can lead to prolonged hospital stays, higher readmission rates and increased mortality. The comments also highlighted the essential role of RDNs in ensuring patients receive the comprehensive care they deserve, particularly by showcasing RDN expertise and skills in the early identification and treatment of malnutrition. The Dietitians in Health Care Communities Dietetic Practice Group worked in collaboration with the Academy on the content that was submitted.
The Academy’s recommendations to CMS included:
- Maintaining malnutrition and "at risk for malnutrition" on the NTA Classification list due to the significant prevalence and impact of malnutrition among the Medicare population, particularly older adults with multiple chronic conditions.
- Standardizing coding practices and criteria for malnutrition within the Resident Assessment Instrument manual and Minimum Data Set to enhance clarity, consistency, and interoperability across health care facilities.
- Supporting best practices for malnutrition care through the use of evidence-based tools such as the subjective global assessment for identifying and diagnosing malnutrition across the health care continuum.
This acknowledgment from CMS marks a significant step forward in safeguarding the recognition of malnutrition within the NTA component. The Academy will continue to work closely with CMS to ensure that malnutrition remains a priority in patient care.
Read the final rule (note: malnutrition is addressed on page 64098).
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