This law provides for the licensure of dietitians, and only those with a license may provide nutrition care. However, in 2021 the law was updated to include a new exemption for unlicensed practitioners, but this created new problems of its own.
The new law states that the dietetics licensure requirement does not apply to:
“A person credentialed in the field of nutrition from providing advice,
counseling, or evaluations in matters of food, diet, or nutrition to the extent such acts are within the scope of practice listed by the credentialing body and do not constitute medical nutrition therapy;”Under this law you cannot advertise or be perceived as “assessing nutritional needs of individuals and groups” etc. You also cannot do or say anything that would give the impression that you are licensed, registered, or call yourself a nutritionist or dietitian.”
Additionally, the state requires that an unlicensed practitioner provide, prior to performing any services, the following:
(1) The person’s name and title;
(2) The person’s business address and telephone number;
(3) A statement that the person is not a dietitian licensed by the state of Missouri;
(4) A statement that the information provided or advice given may be considered
alternative care by licensed practitioners in the state of Missouri; and
(5) The person’s qualifications for providing such information or advice, including
educational background, training, and experience.
Before the new exemption, Missouri had very little room for unlicensed practitioners.
You could practice nutritional care as a part of self-care or gratuitous care by a friend or family member. You could also provide general nutrition information as to the use of food, food materials, or dietary supplements, as well as distribute nutrition literature, so long as you do not call yourself a dietitian or nutritionist.
If you work in the military services or federal facilities, or if you are a licensed health care, you are not restricted from performing nutritional care so long as the activities are within the scope of practice. You can market or distribute food, food materials, or dietary supplements and further explain how to use or to prepare those products.
If you are pursuing a degree in dietetics from an accredited school or program, you can practice dietetic and nutrition services if the services constitute a part of the supervised course of study. If you do partake in practices, you must be designated by a “student” or “trainee” title.
The new exemption appears to open the door for greater unlicensed practice, but there are some red flags to be aware of. The exemption has several terms such as “field of nutrition,” and “credentialed” which are not defined. Under the law, the only “field of nutrition” that is recognized is dietetics, and the only credential is the dietetics credential.
We must consider how a state investigator would interpret the law, and how the state would enforce it against a holistic practice. Therefore, out of an abundance of caution, practitioners should continue to avoid anything which may give the impression that they are attempting to diagnose, treat, or cure a disease.
Whenever possible, source advice, guidance, and education from publicly available resources, keep careful client notes, and avoid all medical terminology.
Source: Missouri Dietetics Practice Act Title 22, Chapter 324, Sections 324.200 to 324.225