Registered Dietitian Medical Statements

Why It Matters 

Prior to the 2024 final rule, only State licensed healthcare professionals could provide medical statements for participants with disabilities that require meal modifications. Beginning October 1, 2025, Registered Dietitians (RD) and Registered Dietitian Nutritionists (RDN) will be able to provide medical statements. RDs are not required to be licensed to provide medical statements, as some states do not have licensing requirements for RDs, however RDs located in a state where licensing is required must be licensed to provide a medical statement. 

Questions and Answers 

1. When is a medical statement required to support meal modification requests for disability reasons?

A medical statement is only required by USDA when the requested modification cannot be accomplished within the Program meal pattern requirements (7 CFR 210.10(m)(1)(i), 220.8(m), and 226.20(g)(1)(i). However, Program operators may choose to require a written medical statement for all disability meal modifications, even those that fall within the Program meal pattern requirements. Program operators should consider the burden of requiring medical statements and must inform parents, guardians, and their children, if age appropriate, of the process for requesting meal modifications (7 CFR 210.10(m)(1)(ii), 220.8(m), and 226.20(g)(1)(i)). 

2. In situations when a medical statement is necessary, what must be included in the medical statement?

A medical statement must include: 

• Information about the participant’s disability that allows the Program operator to understand how the disability restricts the participant’s diet,  
• An explanation of how to accommodate the participant’s disability, and  
• The food or foods that must not be served as well as recommended alternatives, in the case of a modified meal. 

3. Which professionals may submit medical statements on behalf of participants with disabilities?

State licensed healthcare professionals and registered dietitians may write medical statements to request meal modifications on behalf of participants with disabilities in the school meal programs (7 CFR 210.10(m)(1)(i)) and CACFP (7 CFR 226.20(g)(1)(i)). The requirement to accept medical statements from registered dietitians must be implemented by July 1, 2025, for school meal programs, and October 1, 2025, for CACFP. Program operators have the option, but are not required, to implement this change prior to the implementation date. 

4. How is “State licensed healthcare professional” defined in school meal program and CACFP regulations?

A State licensed healthcare professional is defined as an individual who is authorized to write medical prescriptions under State law (7 CFR 210.2 and 226.2). This may include, but is not limited to, a licensed physician, nurse practitioner, or physician assistant, depending on State law. Program operators should contact their State agency with any questions about which professions are included in this definition within their State. 

5. Who is a “registered dietitian” or “registered dietitian nutritionist”?

The terms “registered dietitian” (RD) and “registered dietitian nutritionist” (RDN) are equivalent credentials. Both are nutrition healthcare practitioners, credentialed by the Commission on Dietetic Registration. RDs and RDNs are required to complete specific educational requirements, from an accredited dietetics program, including a supervised practice requirement; pass a national exam; and continue learning through ongoing education. In addition to RD/RDN credentialing, many States have regulatory laws and licensure requirements for RDs. 

6. Are RDs providing medical statements required to be licensed?

No. Only RDs who practice in States that require State licensure must be licensed. Some States do not have licensing requirements and are therefore excepted (see map). Most States require RDs to hold a State license or certification to legally practice or use a protected title within that State. Requirements vary from State to State. Visit this Academy of Nutrition and Dietetics’ website for more information: licensure map and statutes by State. 

7. Are RDs who are employed by local Program operators or State administering agencies allowed to write medical statements for participants?

RDs submitting medical statements must follow their State regulations as well as the Code of Ethics for the Nutrition and Dietetics Profession. As a best practice, healthcare professionals submitting medical statements should have an established professional patient relationship with the individual requesting the reasonable accommodation. Program operators with questions should contact the State administering agency for assistance. 

8. Can Program operators accept medical statements from healthcare professionals licensed in a different State than where the school, child and/or adult care institution, or facility serving the participant is located?

USDA regulations do not require healthcare professionals providing medical statements to be licensed by and operating in the State where the school, child and/or adult care institution, or facility serving the participant is located. However, individual States may have these requirements. Healthcare professionals must adhere to the healthcare regulations for the States in which they are licensed. Program operators are strongly encouraged to communicate with State agencies administering the Child Nutrition Programs in their State should they require tailored guidance. 

 

Read the full Guidance on the Requirement to Accept Medical Statements from Registered Dietitians for Schools and Child and Adult Care Institutions and Facilities (CACFP 07-2025) which also provides additional resources.