The Dietitian Licensure Compact is a legally binding agreement among states that provides a pathway to practice through which dietitians can obtain compact privileges which authorize practice in states where they are not licensed. A state must enact the compact model legislation via a state’s legislative process to join.

The compact:

• Facilitates multistate practice.
• Enhances license portability when changing state of residence.
• Expands employment opportunities into new markets.
• Improves continuity of care when patients or providers relocate.
• Supports relocating military spouses.
• Reduces burden of maintaining multiple licenses.

The Dietitian Licensure Compact is similar in form and function to professional licensure compacts for nurses, physical therapists and psychologists. Dietitians who are licensed in one compact member state can practice in another member state by obtaining a compact privilege.

A compact privilege is the legal authorization for a dietitian to practice in a remote state where they are not licensed. A dietitian must hold an active and unencumbered license in their home state and meet additional eligibility criteria to be eligible for a compact privilege. A dietitian applies for a compact privilege and may begin legally working in the new state when eligibility is verified, jurisprudence requirements are met and all fees are paid.

As stated in section 4 of the compact, eligible dietitians must currently hold the RDN credential or have satisfied all of the following: completion of a programmatically accredited education program, completion of a programmatically accredited planned, documented, supervised experience in dietetics and nutrition and successful completion of the RDN examination. 

A dietitian providing care in a remote state under a compact privilege will function within the scope of practice as individuals who are licensed in that state. It is the dietitian’s responsibility to know what they are authorized to do in the remote state based on that state’s practice act. States retain their sovereignty over the practice of dietetics within their boarders.  

The compact member states will set up the fee structure through rules. With other compacts, the fee for a compact privilege is typically less than the fee for a license. The fee for the compact privilege to practice will be up to the member states to set.

As stated in section 2 of the compact, a home state is the licensee’s primary state of residence. A licensee using the compact must hold an active, unencumbered license issued by their primary state of residence to be eligible for compact privileges.

The Dietitian Licensure Compact will have no impact on a state’s requirements for initial license or license renewal.

The compact is an alternative, optional pathway to practice by obtaining a compact privilege. 

Because dietitians need to obtain individual compact privileges in each state where they want to practice, regulators will know who has compact privileges in their state. States will have access to the compact commission’s data system and will be able to view this information as needed. Just as a regulator can currently see who has a license in their state, regulators will be able to know who has compact privileges to practice in their state.

Practitioners must complete the continuing education requirements to maintain their home state license. They do not complete continuing education in remote states where they hold compact privileges.

The compact commission is a government agency established by the compact. The compact commission will be comprised of one delegate from each member state. The compact commission writes rules and bylaws to administer and implement the compact. As stated in section 8 of the compact, commissioners will be a designee from each participating state’s licensing authority. The compact commission is not a licensing board. It cannot affect state licensing requirements or take action against a licensee. 

CSG anticipates that the model compact legislation will be finalized in time for states to enact during the 2024 legislative sessions.

Fifteen professions have active interstate compacts for professional licensure:

• • Interstate Medical Licensure Compact (IMLC)
  • Nurse Licensure Compact (NLC) and Advanced Practice Registered Nurse Compact (APRN Compact)
  • Recognition of Emergency Medical Services Personnel Licensure Compact (The EMS Compact)
  • The Physical Therapy Compact (PT Compact)
  • The Psychology Interjurisdictional Compact (PSYPACT)
  • Audiology and Speech-Language Pathology Interstate Compact (ASLP-IC)
  • The Occupational Therapy Licensure Compact (OT Compact)
  • The Counseling Compact
  • Social Work Compact
  • Interstate Teacher Mobility Compact (ITMC)
  • Dentist and Dental Hygienist Compact
  • Interstate Massage Compact (IMpact)
  • Cosmetology Compact
  • PA Compact

The following states would not be able to participate because they do not license or certify dietitians: California, Colorado, Virginia, Michigan, and Arizona. It is the aim that all other states, if they pass the compact legislation, will be able to participate in the compact.

To participate in the compact, a dietitian must hold a license issued by their home state. The compact defines home state as the licensee’s primary state of residence. A license from a state other than the home state does not qualify one to participate in the compact. Other licenses can still be used to practice in the state that issued them but cannot be used for participation in the compact. If you do not hold a license in the state where you reside, you must obtain a license from your home state prior to using the compact to obtain privileges to practice in other compact states.

The compact requires the dietitian to hold a license or certification issued by their home state.  

Some states issue a credential but call it certification rather than licensure. The compact defines license as an authorization to use a title or practice issued by a state. Thus, regardless of what the state calls the authorizing credential, if a state issues an authorization to utilize a title or practice (such that the state then regulates the practice of that licensed or certified practitioner) that would satisfy the requirement.

States might have existing reciprocity or universal licensure recognition processes. These licensure pathways still require the dietitian to submit an application to the new state, pay the full licensure fees, and typically require a board to review the application to determine substantial equivalency of the previous state’s licensing requirements. This pathway makes it easier to get a license in one single state but does not reduce barriers for dietitians who wish to practice in multiple states.

An interstate compact is an additional pathway to practice for practitioners who want to be mobile or work in multiple states. If the licensee meets the requirements in the compact, they are able to practice in the other compact member states without having to wait for a determination from a licensing board. Practitioners simply apply for a privilege to practice in other compact states. A privilege to practice generally costs significantly less than an initial license and is issued more expediently.

Unlike universal licensure recognition, compacts reduce barriers to practicing in multiple states and provide for two-way reciprocity rather than simply making it easier for out-of-state practitioners to come into a state.

The compact commission will require a fee for issuance of a compact privilege. The compact also gives the remote state the ability to charge a fee for the compact privilege. The amount of the fee will be set by the compact commission. While we cannot speak to the amount of the fee at this time, we believe the compact commission will set the fees at a reasonable level so as to encourage participation in the compact.

Dietitians will need to obtain a compact privilege in each member state they wish to practice and will need to pay a privilege fee to each state where a privilege is sought.