Pa. Department of Health Clarifies the Delegation of Dietetic Orders in Long-Term Care Facilities

Last Updated: Jul 9, 2019

dietetic-orderRegulations issued in 2016 by the Centers for Medicare and Medicaid Services (CMS) allow delegated dietitians to write dietetic orders for patients in long-term care facilities (LTCs).

Physicians are permitted to delegate dietetic order writing in LTCs to a registered or licensed dietitian or other clinically licensed nutrition professional who is:

  • Under the supervision of a physician
  • Acting within the scope of practice as defined by state law

In its Long-Term Care Provider Bulletin issued on July 3, 2019, the Pa. Department of Health (DOH) clarified that CMS’ regulations are within the scope of practice of dieticians licensed in Pennsylvania. If a physician writes an order delegating the task to the dietician, then they are permitted to proceed with writing dietary orders.

DOH also shared the following:

  • The physician has ultimate responsibility for the resident’s care.
  • A physician must first order the resident’s diet. Only after the physician orders the resident’s diet may the physician then delegate dietary orders to a registered dietitian who can, under this delegation, alter, modify, or change the physician’s original order. The physician shall specifically note in the medical record the delegation to the dietitian to alter/modify/change the original order.
  • The dietician issuing the dietetic order must act under the direction or supervision of the physician.
  • The facility’s policies and procedures must outline the qualifications, status, clinical duties and responsibilities of registered dietitians and delineate the responsibilities of the physician in relation to registered dietitians.
  • The registered dietitian issuing an order for a resident's diet shall act only in accordance with regulatory requirements and policies and procedures.

It is important to note that delegation of dietetic orders is not automatic and does not have to implemented. 

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