Letter Talking Points
These are some of the important reasons that Public Act 333, as it is being written, is so bad for Michigan citizens, our health and our economy. You may use these points in writing letters to the Michigan Dept. of Community Health and the MI Nutrition and Dietetics Board, incorporating your own thoughts and experiences.
1. The licensure statute was written in a way that allows only RD’s to serve as professional members of the rule-making board. There are many qualified nutrition professionals with different training from RD’s who were deliberately excluded from the rule-making process. This makes it next to impossible for rules to be written that do not violate the stipulation that the law not diminish competition.
2. Registered Dietitians receive training that is heavily geared toward careers is food service management, government programs, and medical nutrition therapy. They do not receive adequate training in holistic, preventive nutrition, functional nutrition, or use of herbs and supplements as do holistic health counselors, naturopathic physicians, certified clinical nutritionists, and many other already, well-qualified health and nutritional professionals who desire to offer an integrative or complementary approach to nutrition. Consumers have the right to choose a nutritional professional that fits with their needs and philosophies, and do not need the state to decide for them who they should see.
3. Public Act 333 states the rules must not exceed the minimum level of regulation necessary to protect the public from harm. More harm has come from people not understanding how nutrition can improve or destroy health, than from seeking nutrition counseling. (Include a personal experience reflecting this--have you reversed diabetes, high blood pressure, resolved digestive problems or other chronic health problem, gotten off or reduced medication as a result of nutrition counseling? Have you found a nutritionist who was able to help you in ways a registered dietitian or a doctor was not?)
4. Consider the harm done to individual and public health from making it harder to find practitioners. Excessive regulation will not only eliminate many qualified people, it will make the cost of seeing a nutritionist higher because of the extremely high costs many will have to shoulder in order to qualify. With astronomical health care costs, costs to businesses of unhealthy employees, and the impact on individuals and families of poor health and disease, we should be increasing resources for nutrition counseling, not eliminating them or making it more difficult to qualify as a provider.
5. Public Act 333 states the rules must not diminish competition. The Michigan Dietetic Association by their own admission seek these rules to “protect our scope of practice from uneducated wannabes” (http://www.eatrightmich.org/mdaLink/pdf/Spring2010LINK%2Epdf) If diminishing competition were not the objective, why has there been no recognition and discussion of different types of training, of practices and of credentialing bodies? Under this law, some practitioners such as Naturopathic Physicians whose training in nutrition far exceeds that of Registered Dietitians, would not even qualify for licensure!
6. Why is there no possibility of grandfathering in existing practitioners instead of requiring years of additional, expensive training, supervised clinical hours, and limited exam possibilities? Meeting these requirements will place an unreasonable burden that many will not be able to meet and will therefore put them out of business no matter if 1,2, 4 or more years are given before the law takes effect. Our state cannot afford to put small business people out of business.
7. What evidence is there to prove the public is at risk of harm from currently unlicensed nutrition professionals? If it were such a threat, wouldn’t we have seen data showing harm by now? RD’s have never been licensed in Michigan--has this caused the public harm?
8. Has licensure in the medical field protected consumers from injury or even death thus far? The annual death rate from medical mistakes is over 750,000 from licensed medical professionals. 106,000 of these are from prescription drugs (Null, et al, Death by Medicine). FDA data between 1993 and 1998, shows a total of 184 deaths from herbs and dietary supplements--37/deaths per year. Consumers have a right to seek guidance from professionals who receive training in the use of food and supplements which are unequivocally safer than medication offered by licensed health care professionals. And currently this training is not part of the RD curriculum but is included in many non-RD training programs.
9. More harm to the public has unequivocally resulted from diets based on processed food, sugar, high fructose corn syrup and excessive grain consumption as prescribed by the grain-heavy food pyramid of which the registered dietitians are the chief proponents. RD’s are the purveyors of “hospital food” Both national and state dietetic associations have aligned themselves with junk food manufacturers, as companies such as Kellogg, ConAgra, Coca Cola, Mars, and Hersey’s, and the Soy industry provide significant financial support to their organizations. And yet they feel that RD’s are best qualified to counsel Americans, and in MIchigan, they want all nutritionists to model their training after the RD curriculum.