CNA & BCNS Comments to Federal Agencies

September 6, 2016
BCNS Comment to Centers for Medicare & Medicaid about Diabetes Self Management Training & Diabetes Prevention Program
The Board for Certification of Nutrition Specialists responded to a request from Centers for Medicare and Medicaid (CMS) to submit comments on a proposal that includes plans to expand the Diabetes Self Management Training (DSMT) benefit, and to add the Diabetes Prevention Program (DPP) as a new Medicare benefit. CMS specifically requested identification of existing barriers that prevent more widespread usage of the DSMT benefit, which now stands at approximately 5% of those eligible for it, and comments on utilizing DPP lifestyle coaches as Medicare suppliers.

 

June 6, 2014  

BCNS Comment to HHS Supporting Non-Discrimination Clause of the Affordable Care Act

The Board for Certification of Nutrition Specialists (BCNS) responded to a request for comments from the Dept. of Health and Human Services (HHS) on guidance by the HHS, Dept. of Treasury, and Dept. of Labor to insurers on their responsibilities under the Affordable Care Acts's non-discrimination clause, 2706. 

 

May 16, 2014

CNA Comment to Federal Trade Commission: Identifying and Overcoming Barriers to Competition in Nutrition Services, Part II

The Center for Nutrition Advocacy submitted an additional comment to the Federal Trade Commission following an Academy of Nutrition and Dietetics comment.

 

March 20, 2014  

CNA Comment to Federal Trade Commission: Identifying and Overcoming Barriers to Competition in Nutrition Services, Part I

The Center for Nutrition Advocacy responded to a request for comments from the Federal Trade Commission for their "Examining Healthcare Competition" workshop.

 

October 15, 2013

BCNS Comment on FDA Draft Guidance Restricting Medical Foods

The BCNS commented on proposed FDA Draft Guidance on Medical Foods that would severely restrict the labeling of a product as a "medical food". As drafted the guidance would have prevented, for example, the labeling of therapeutic protein powder with nutraceuticals for the treatment of Type 2 Diabetes as a medical food. Allowing this kind of labeling is key to the increasing recognition of the value of nutrition therapy in healthcare. The BCNS commented that many labeled medical foods do meet the set of requirements outlined by the FDA, and such appropriate labeling allows practitioners and consumers choice and access to these therapeutic products, and removes barriers to the use of therapeutic nutrition healthcare.

 

March 8, 2013

BCNS Request to CMS that Nutrition Services be Expanded Beyond RDs to Nutrition Professionals

The BCNS requested the specific addition of "other nutrition professionals" to an initial Centers for Medicare and Medicaid Services (CMS) policy draft that solely referenced Registered Dietitians.