Iowa law severely restricts the practice of holistic nutrition. Only those who are licensed may provide nutrition care.
The law is very short, and much of what it entails is contained within the regulations. However, in another section of Iowa law, it explicitly states that one must have a license to practice dietetics. However the term “dietetics” is not defined in the law but rather in regulation.
In the Iowa Administrative Code Section 645-81.1, the Board of Dietetics has defined for itself the term “dietetics” as “the integration and application of principles derived from the sciences of nutrition, biochemistry, physiology, food management and from behavioral and social sciences to achieve and maintain an individual’s health.”
In the statute, laws as opposed to regulations, in section 147.2 it defines that a license is required:
1. A person shall not engage in the practice of medicine and surgery, podiatry, osteopathic medicine and surgery, psychology, chiropractic, physical therapy, physical therapist assisting, nursing, dentistry, dental hygiene, dental assisting, optometry, speech pathology, audiology, occupational therapy, occupational therapy assisting, orthotics, prosthetics, pedorthics, respiratory care, pharmacy, cosmetology arts and sciences, barbering, social work, dietetics, marital and family therapy or mental health counseling, massage therapy, mortuary science, polysomnography, athletic training, acupuncture, nursing home administration, or sign language interpreting or transliterating, or shall not practice as a physician assistant or a hearing aid specialist, unless the person has obtained a license for that purpose from the board for the profession.”
(Source: Title IV, Subtitle 3, Chapter 147)
Since the word “dietetics” is not defined, we have to look to what is defined. Within the regulations for this law, in 645—81.1 we see the following:
“Nutrition assessment” means the evaluation of the nutrition needs of individuals and groups based upon appropriate biochemical, anthropometric, physical, and dietary data to determine nutrient needs and to recommend appropriate nutritional intake, including enteral and parenteral nutrition.
“Nutrition counseling” means advising and assisting individuals or groups, with consideration of cultural background and socioeconomic status, about appropriate nutritional intake by integrating information from the nutrition assessment with information about food and other sources of nutrients and meal preparation.
These refer to statements made in section 645.81.2 regarding “Nutrition care”:
“645—81.2(152A) Nutrition care. The primary function of dietetic practice is the provision of nutrition care services that shall include:”
Here it breaks this down to include:
“Assessing the nutrition needs of individuals”
“Establishing priorities, goals, and objectives that meet nutrition needs”
“Providing nutrition counseling concerning health and disease.” (Note: Holistic health does not diagnose, treat, or cure diseases)
“Developing, implementing, and managing nutrition care systems” (Note: This is not further defined so it’s up to the board to decide what nutrition care systems means)
“Evaluating, making changes in, and maintaining appropriate standards of quality in food and nutrition services.”
Taken as a whole, while the law does not explicitly state that only someone with a license is allowed to practice dietetics, it does state that a license is required for dietetics, and then it defines dietetic practice to include a broad set of functions that could be interpreted to mean only someone with a license may perform them.
However, some exemptions do exist:
Section 152A.3, which covers exemptions states:
5. Individuals who do not call themselves dietitians but routinely, in the course of doing business, market or distribute weight loss programs or sell nutritional products and provide explanations for customers regarding the use of the programs or products relative to normal nutritional needs.
6. Individuals who provide routine education and advice regarding normal nutritional requirements and sources of nutrients, including, but not limited to, persons who provide information as to the use and sale of food and food materials including dietary supplements.
Unfortunately the law, and its regulations, do not define “routine education and advice” ergo out of an abundance of caution, this should be interpreted similar to “general health and wellness” exemptions.
Source: Title IV, Subtitle 3, Chapter 152A