Your letters and conversations will be more persuasive if you can take any of the points below (or any others we haven't thought to include) and write something that is personal to your thoughts, or to how you, your family, or your clients (if you are a professional) will be affected by this law.
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 nutritional 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. This law is about monopoly and eliminating perceived competion.Registered Dietitians are only one type of nutritionist. They receive training that is heavily geared toward careers in food service management, government programs, and medical nutrition therapy for acute, hospitalized patients and disease management. They receive minimal training in holistic, preventive nutrition, functional nutrition, or use of herbs and supplements.This law does not recognize credentials and training of holistic health counselors, naturopathic physicians, masters and doctoral level nutritionists, certified clinical nutritionists, certified nutrition specialists, and many other well-qualified health and nutritional professionals trained in evidenced-based nutrition.
4. This law will put entrepreneurs out of work which MI can ill afford. And, since 92% of registered dietitians work within institutions, it will diminish the supply of nutrition practitioners providing wellness and prevention services to non-hospitalized patients, a critical need if we are to reduce health care expenditures for chronic disease.
4. People should have the right to choose their form of nutritional therapy from a variety of professionals with different approaches whether in the field of clinical nutrition or in the fields of dietetics.
5. 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. The promoters of this law claim the public is being harmed without this law, yet there is no such evidence of harm. RD's have never been licensed in Michigan-- has this caused the public harm? 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?
6. 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.
7. 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." 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!
8. 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 there fore 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.
9. 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). 2008 data from the American Association of Poison Control Centers reports ZERO deaths from any type of herbs, supplements, homeopathics, vitamins or minerals. Consumers have a right to seek guidance from professionals who receive training int he use of food, herbs 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 (by their own reporting) but is included in many non-RD training programs.
10. More harm to the public 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. Both national and state dietetic associations have aligned themselves with junk food manufacturers, as companies such as Kellogg, ConAgra, Coca Cola, Mars, and Hershey'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.
11. Include a personal experience 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? What would this law mean for you as a practitioner or as a consumer?