I fully support all the enhancements in RD privileges recommended. I suggest that theraputic diets be clarified to include both enteral and parenteral nutrition support modalities. The evidence cited in this documents describes RD input resulting in significant savings and improved outcome when RDs managed parenteral nutrition support. I am concerned that "Therapuetic Diet" will be interpreted as only food that is consumed by the patient off a meal tray. RDs can make the biggest impact (and currently do), by managing enteral and parenteral nutrition support so I recommend making sure that the scope of managing these therapies are spelled out in this regulation clarification.
Katie Farver
This is comment on Proposed Rule
Medicare and Medicaid Programs: Part II - Regulatory Provisions to Promote Program Efficiency, Transparency, and Burden Reduction
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