Comment on CMS-2026-2377-0002

Comment Regarding CMS-1848-P: Shared Medical Appointments and Medical Nutrition Therapy To the Centers for Medicare & Medicaid Services: I am a Registered Dietitian Nutritionist and independent nutrition care provider writing to express concern regarding the proposed treatment of Medical Nutrition Therapy (MNT) within Shared Medical Appointments (SMAs). I support CMS’s efforts to expand coordinated, evidence-based care for Medicare beneficiaries with chronic disease. However, I am concerned that under the proposed policy, MNT provided by a Registered Dietitian during an SMA could be bundled into the payment made to the practitioner billing for the SMA rather than remaining separately reimbursable under CPT 97804. MNT is an established Medicare Part B benefit. Registered Dietitians and qualified nutrition professionals enroll in Medicare as independent providers, and their MNT services are separately recognized and reimbursed. Many interventions contemplated within SMAs—including nutrition intervention, dietary behavior change, chronic disease self-management, and lifestyle modification—fall directly within the expertise of Registered Dietitians. An RD may therefore provide a substantial portion of the therapeutic intervention while receiving no separate reimbursement for that professional service. This risks recreating a longstanding problem in dietetics: nutrition care being absorbed into another healthcare service as an operating expense rather than recognized as a distinct professional service. It could also disproportionately affect independent RDs and small practices. Large healthcare systems may be able to compensate an RD from a bundled payment, while independent RDs collaborating with physicians and other practitioners may not have that option. This could discourage interdisciplinary collaboration and ultimately reduce Medicare beneficiaries’ access to specialized nutrition care. CMS should distinguish between duplicate billing and distinct professional services delivered during a coordinated encounter. When a Medicare-enrolled RD independently performs and documents medically necessary MNT, and the beneficiary meets Medicare’s MNT coverage requirements, that service should remain separately reimbursable. Appropriate safeguards can ensure that the same practitioner time is not counted toward both services. I respectfully request that CMS preserve separate payment for CPT 97804 when MNT is personally furnished and separately documented by a qualified RD during an SMA. Alternatively, CMS should establish an add-on payment mechanism recognizing MNT furnished by an RD as part of the shared appointment. Interdisciplinary care should not require one healthcare profession’s services to become financially invisible within another profession’s billing. Preserving recognition and reimbursement of independently provided MNT would support CMS’s goals of coordinated chronic disease care while protecting patient access to qualified nutrition professionals. Thank you for the opportunity to comment on CMS-1848-P. Respectfully, Registered Dietitian Nutritionist Independent Nutrition Care Provider