Regulatory Impact

 Key Elements of Michigan Dietetics/Nutrition Licensing Law:

Bottom Line: It is illegal to practice most standard nutrition counseling in Michigan without a nutrition/dietetics license, unless you fall under very limited exceptions. This does not simply mean the use of a certain title is restricted – it means it is illegal to conduct the activity, regardless of what you call yourself.

Here are the key things you need to know to understand how the law impacts you:

  1. Do you engage or plan to engage in ANY of these standard nutrition counseling activities that the law restricts?

“(i) Assessing the nutrition needs of an individual or group of individuals based upon biochemical, anthropometric, physical, and dietary data, determining the resources and constraints to meet the nutrition needs of that individual or group of individuals, and recommending proper nutrition intake to satisfy those needs.

(ii) Establishing priorities, goals, and objectives to meet the nutrition needs of the individual or group of individuals based on available resources and constraints.

(iii) Providing nutrition counseling regarding health and disease.

(iv) Developing, implementing, and managing a nutrition care system.

(v) Evaluating, adjusting, and maintaining a standard of quality in dietetics and nutrition care services. OR

(vi) Providing medical nutrition therapy.”

If you do, you will be breaking the law, unless you either obtain a license, or you fall under an exemption to the law. Let’s look at the exemptions.

  1. Are you exempt from the licensing requirement?

    1. Do you possess a separate Michigan license that includes nutrition counseling in its scope of practice? see whether your profession is exempt [link]

    2. Are you merely discussing food or supplements and are a distributor or retailer (eg vitamin department at Whole Foods)?

    3. Are you only conducting a weight loss program under the supervision of a Michigan license-holder?

If you are not exempt, then you must obtain a nutrition/dietetics license to conduct those restricted activities in (1) above.

  1. To obtain a license, you must fulfill ALL three requirements of Education, Supervised Experience, and an Exam:

  1. Education: You must have either:

    1. a "Baccalaureate, Master's or Doctoral degree from a United States regionally accredited institution of higher education with a major course of study in human nutrition, nutrition education, foods and nutrition, dietetics, or food systems management" or

    2. If you don’t have one of those degrees, you MAY qualify for the academic component if you have an “equivalent course of study”. As of July 2010, the Licensing Board had adopted for the draft rules the "equivalent course of study" below.

1) basic general chemistry

2) organic chemistry

3) biochemistry

4) microbiology

5) anatomy/physiology or human physiology:

6) statistics.

AND

a) human nutrition in health & disease - 9 semester hours

b) nutrition & human development - sem 3 hours

c) food safety & sanitation – 2 sem hours

d) preventive nutrition & wellness – 3 sem hours

e) nutrient composition of foods & food science – 6 sem hours

f) nutrition assessment, nutrition therapy, nutrition evaluation (medical nutrition therapy) -8 sem hours

g) counseling strategies, behavior change, communication skills – 3 sem hours

  1. Practice Experience: You must complete "900 hours of postdegree or planned continuous preprofessional experience supervised by a licensed health care professional who has experience and knowledge in the provision of dietetics and nutrition care services or by a licensed dietitian or nutritionist"?

  2. Exam (except PhDs): You must pass the Registered Dietician (RD) exam (from Commission on Dietetic Registration); or the Certified Nutrition Specialist (CNS) exam (from the Certification Board for Nutrition Specialists? ( PhDs with a major course of study in human nutrition, nutrition education, foods and nutrition, dietetics, or food systems management, or an equivalent course of study do not need to fulfill the exam requirement.)