Florida's Telehealth Registration for Dietitians

Florida is one of the states where a telehealth dietitian cannot simply rely on an out-of-state license. Florida law says "No person may engage for remuneration in dietetics and nutrition practice or nutrition counseling or hold himself or herself out as a practitioner of dietetics and nutrition practice or nutrition counseling unless the person is licensed" (Fla. Stat. § 468.504). Florida is not a member of the Dietitian Licensure Compact either.

There is a lighter alternative to a full license. Since 2019, Florida's telehealth statute has let a health care professional licensed in another state register with the relevant Florida board and treat Florida patients by telehealth. Dietitians are covered: the statute's definition of a telehealth provider includes professionals licensed under part X of chapter 468, which is Florida's Dietetics and Nutrition Practice Act.

Who can register?

Under § 456.47(4)(b), the board registers an out-of-state professional who:

1. Completes an application in the format the Department of Health prescribes.
2. Holds an active, unencumbered license issued by another state, DC or a US territory that is "substantially similar" to the corresponding Florida license.
3. Has not been the subject of license discipline during the five years before applying.
4. Designates a registered agent for service of process in Florida.
5. Shows the required professional liability coverage or financial responsibility, including coverage for telehealth services to patients outside the provider's home state.

The Department checks the information against the National Practitioner Data Bank. A professional whose license is under a pending disciplinary investigation, or has been revoked anywhere, may not register (§ 456.47(4)(d)).

Why can't a California RD use it?

Because the registration rests on a license from another state. California, Colorado, Virginia and Arizona issue no dietitian license, and Michigan and New Jersey are not issuing one while their regulations are not in effect. A dietitian whose only credential is CDR registration has nothing for Florida to register against. Registration with CDR is a national certification, not a state license. A California dietitian who wants Florida clients would need either a license from another state first (then register in Florida) or a full Florida license.

A license from a title-only state raises a different question. Texas issues a license that protects the "LD" title rather than practice. Whether Florida treats it as "substantially similar" is a call for the Florida board; ask before relying on it.

What does the registration not allow?

• No in-person care. A registrant "may not open an office in this state and may not provide in-person health care services to patients located in this state" (§ 456.47(4)(f)).
• No practice beyond Florida's scope. You practice within the scope Florida law sets for dietitians, at the same standard as a Florida provider seeing the patient in person (§ 456.47(2)(a) and (4)(a)).
• No skipping disclosures. Your website must prominently link to the Department's page listing registrant information (§ 456.47(4)(c)).

The Department publishes a public list of registrants that includes your out-of-state license number, Florida registration number, five-year disciplinary history, malpractice insurer and policy limits, and registered agent (§ 456.47(4)(h)). Expect clients and employers to look you up there.

What ongoing duties come with it?

You must notify the Florida board of any restriction or disciplinary action taken or pending against your license in any state within 5 business days (§ 456.47(4)(d)). The board may discipline a registrant who fails to report, is disciplined elsewhere, violates the statute, or commits an act that is grounds for discipline under Florida law, up to suspending or revoking the registration (§ 456.47(4)(i)). Medical records rules apply as they would to in-person care (§ 456.47(3)).

Two situations are exempt from registering at all: services in response to an emergency medical condition, and services in consultation with a Florida-licensed professional who has ultimate authority over the patient's diagnosis and care (§ 456.47(6)).

Is a registration or a full Florida license better?

It depends on what you plan to do in Florida.

• Registration fits a telehealth-only dietitian with a clean license in another state who does not need the Florida title and will never see Florida clients in person.
• A full license fits a dietitian who may move to Florida, see clients in person there, wants to hold out as Florida-licensed, or whose payers or employer require a Florida license number. Florida waives its exam for a CDR-registered RD or RDN, or for a Certified Nutrition Specialist, who meets the other qualifications (§ 468.509(4)), and offers licensure by endorsement with background screening (§ 468.513). Applicants for licensure must submit to background screening (§ 468.509(2)).

Check with any payer before choosing. A registration authorizes practice, but some insurers credential only Florida licensees. Our sister site's post on Florida telehealth registration for physicians covers the same statute from the medical side, and its overview of telehealth registration states compares Florida with others.

How do you apply?

Gather your license verification, the registered agent designation, proof of liability coverage, and answers to the discipline questions before you start. The Department checks the National Practitioner Data Bank, so make sure anything reported there is something you have disclosed. Then complete the application with the Department of Health, pay any fee it charges, and submit.

We prepare the registration for you. Our Telehealth Registration service is $299 per state: we assemble the documents, check them against the statute, and track the file while you review, sign, pay the Department and submit. If a full Florida license suits you better, our Full State License Application is $749. See Florida's requirements or our pricing.