CMS Payment System Rule Acknowledges RDNs' Role in Hospital Care

The Academy’s advocacy has resulted in significant wins for the profession and quality care in the payment system that the Centers for Medicare & Medicaid Services (CMS) uses to reimburse hospitals for inpatient services. The final rule included three specific positive outcomes for nutrition and dietetics professionals related to payment models, expanded quality measures for malnutrition and star ratings. The integration of Academy recommendations into the final rule reinforces the role of RDNs in interprofessional care and indicates well-earned respect for the profession by the agency.

Earlier this year, CMS acknowledged the pivotal role RDNs play in enhancing patient outcomes and managing care transitions in the Inpatient Prospective Payment Systems (IPPS) Proposed Rule. In response, the Academy advocated for the inclusion of RDNs as key collaborators in a new payment framework, Transforming Episode Accountability Model (TEAM). CMS has acknowledged and confirmed the recommendation to include RDNs as eligible providers in the final rule for this mandatory, episode-based payment model that holds hospitals accountable for quality of care for up to 30 days post-discharge for specific procedures. RDNs will now be well-positioned to support patient care transitions and improve outcomes during the critical post-discharge period.

In the TEAM model, RDNs are considered “collaborators,” which means their time and contributions are financially accounted for and recognized. This will allow RDNs to participate in financial sharing arrangements, where a portion of any incentive-based payments earned is distributed according to contractual agreements. These incentive-based payments, known as "gainsharing payments," are made by a TEAM participant, such as a hospital, to a TEAM collaborator, for example an outpatient facility, private practice or skilled nursing facility — all common RDN workplaces — as part of a "sharing arrangement.” These payments are designed to distribute the financial benefits or gains resulting from successful patient care coordination and management within the TEAM model. To ensure compliance with legal and anti-fraud regulations, these payments must adhere to specific guidelines and be properly documented.

Additionally, the Academy-championed Global Malnutrition Composite Score (GMCS) was updated in the IPPS rule and expanded to include all adults 18 years of age and older. The change will begin in the 2026 reporting period and become part of payment determination in 2028. The Academy and strategic partners advocated for the more inclusive measure, which was previously limited to those 65 years and older. CMS encouraged commenters in its final rule to begin engaging in this work, which could result in both improved clinical outcomes and substantial financial savings on subsequent medical care for hospital systems despite the one-year gap period. GMCS was the first nutrition-focused quality measure to be included in the payment system, a major step forward for nutrition and dietetics professionals.

Finally, CMS acknowledged the Academy’s comments concerning long-term care hospitals star ratings that recommended integrating nutrition-related measures, with a focus on conditions such as cardiovascular disease, diabetes and malnutrition. Long-term care hospitals receive star ratings from CMS related to three quality domains: health inspections, staffing and quality measures based on the minimum data set. CMS noted that the agency will consider the Academy’s and other recommendations in future updates to the star ratings.

View the final rule.