Academy Comments re NPDB 11132017

November 13, 2017
HRSA Information Collection Clearance Officer
Room 14N39
5600 Fishers Lane
Rockville, MD 20857
Re: National Practitioner Data Bank for Adverse Information on Physicians and Other Health Care
Practitioners-45 CFR Part 60 Regulations and Forms, OMB No. 0915-0126-Revision (OMB No. 09150126)
Dear Sir or Madam,
The Academy of Nutrition and Dietetics (the “Academy”) appreciates the opportunity to submit
these comments to the Health Resources and Services Administration (HRSA) related to its June
10, 2016 public comment request “National Practitioner Data Bank for Adverse Information on
Physicians and Other Health Care Practitioners-45 CFR Part 60 Regulations and Forms, OMB No.
0915-0126-Revision” (OMB No. 0915-0126). Representing more than 100,000 registered
dietitian nutritionists (RDNs),1 nutrition and dietetic technicians, registered (NDTRs), and
advanced-degree nutritionists, the Academy is the largest association of food and nutrition
professionals in the United States and is committed to improving the nation’s health through food
and nutrition across the lifecycle. Every day we work with Americans in all stages of life — from
prenatal care through end of life care — providing nutrition care services and conducting
nutrition research.
The Academy is committed to the NPDB’s purpose “to improve health care quality, protect
the public, and combat health care fraud and abuse in the United States,” and works closely
with state licensure boards to ensure dietetics and nutrition practitioners meet high
standards of competency, quality and professional practice. We support HRSA’s proposed
changes “to eliminate redundant and unnecessary forms, improve user error recovery, and
improve overall data integrity.”
The NPDB, by collecting significant data from various reporting entities, has the potential to
improve the quality of and access to health care by enhancing transparency, facilitating quality
practice across state lines, and promoting telehealth. In addition, practitioners are made more
accountable thus enhancing professional excellence. The Academy supports the intent of and
believes that the NPDB has the potential “to improve the quality of health care by encouraging
hospitals, State licensing boards, professional societies, and other entities providing health care
services to identify and discipline those who engage in unprofessional behavior, and to restrict the
ability of incompetent health care practitioners, providers, or suppliers to move from State to
State without disclosure of previous damaging or incompetent performance.”

The Academy recently approved the optional use of the credential “registered dietitian nutritionist (RDN)” by
“registered dietitians (RDs)” to more accurately convey who they are and what they do as the nation’s food and
nutrition experts. The RD and RDN credentials have identical meanings and legal trademark definitions.
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RDNs are qualified Medicare providers eligible to independently provide and bill for medical
nutrition therapy for multiple chronic diseases and conditions. Although RDNs are licensed to
provide services in most states (typically as “licensed dietitian nutritionists” or LDNs), there are a
handful of states (including California), that do not license RDNs and thus have no dietetics
licensure boards that could report incompetent practice. The Academy seeks confirmation from
the NPDB that these health care entities will be required to report RDNs. Further, we seek
clarification whether these health care entities will be required to report RDNs (and other
providers) in states in which the state does not license them to provide services. At this time, we
note that publicly available data for RDNs does not appear to be available for particular states that
do not license them to practice. In addition, the Academy asks HRSA to publicly disseminate a list
of professional societies currently reporting to the NPDB.
We sincerely appreciate the opportunity to offer comments on the NPDB information collection,
and would welcome the opportunity to discuss the above issues and the ability of the Academy to
effectuate the NPDB’s purpose with the NPDB team at HRSA in the near future. Specifically, we
request a meeting to discuss the processes by which all health care practitioners are currently and
will prospectively be reported to the NPDB from various entities. Please contact either Jeanne
Blankenship by telephone at 312-899-1730 or by email at jblankenship@eatright.org or Pepin
Tuma by telephone at 202-775-8277 ext. 6001 or by email at ptuma@eatright.org with any
questions or requests for additional information.
Sincerely,

Jeanne Blankenship, MS RDN
Vice President
Policy Initiatives and Advocacy
Academy of Nutrition and Dietetics

Pepin Andrew Tuma, Esq.
Senior Director
Government & Regulatory Affairs
Academy of Nutrition and Dietetics

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