Where the Client Is: The Licensing Rule for Telehealth RDNs

The licensing rule for telehealth dietitians fits in one line: the client's physical location during the session decides which state's law applies. Not the client's home address, not your office, not your employer's headquarters. Most licensing mistakes in telehealth nutrition come from getting this one fact wrong.

Who says the client's location controls?

Every authority that has addressed it for dietitians.

• The Commission on Dietetic Registration (CDR). Its February 2026 credentialing tip says practitioners serving clients in other states must comply with the licensure and telehealth laws "of the states in which the patients/clients are physically located at the time of service," unless an exemption applies or the state does not regulate dietetics through licensure or certification.
• The Academy of Nutrition and Dietetics. "The legal status of cross-border/telehealth practice is generally determined by the location of the patient or client."
• State law. Florida deems telehealth services to occur "at the place where the patient is located at the time the act is performed" (Fla. Stat. § 456.47(5)). The Texas licensing agency frames its title rule around clients "located in Texas."
• The Dietitian Licensure Compact. Its model law holds dietitians to the practice laws "in the State in which the patient is located at the time care is rendered" (§ 1.I). No state issues privileges yet, but the rule is the same.

Does it matter where you are sitting?

For the client's state, no. A dietitian licensed only in Oregon who sees a Florida client is practicing in Florida for that session. Your own location can matter for other reasons (your home state's rules on practicing there, your employer's policies, the compact's home-state concept once it opens), but it does not substitute for the client's state.

What about clients who travel?

This is where the rule bites. The session takes place wherever the client is that day.

• A vacation. Your Ohio client calls in from a beach rental in South Carolina. For that session, you are practicing in South Carolina.
• College students. A student whose family lives in Illinois spends nine months a year in Indiana. Sessions during the semester are Indiana sessions.
• Seasonal residents. A client who winters in Florida and summers in Michigan moves your licensing needs with them.

Some states anticipate short stays. Georgia lets a nonresident registered dietitian practice "for five days without a license or up to 30 days per year with licensure from another state" with substantially equal requirements (O.C.G.A. 43-11A-18(4)). The District of Columbia allows telehealth to an existing client who is temporarily in DC (D.C. Code § 3-1201.05(e)). Idaho and Montana have similar continuity-of-care exceptions for established patients who are temporarily present. Many states have no such exception at all, so the safe default for a traveling client is to check that state before the session or reschedule.

Is a client's home address enough to go on?

No. An address on an intake form tells you where the client lives, not where they will be on a given Tuesday. Delaware's telehealth law makes location part of a valid provider-patient relationship, requiring "thorough verification and authentication of the location and, to the extent possible, identity of the patient" (24 Del. C. § 6003(a)(1)). Even where a state does not say so in statute, a recorded location is your evidence if a board ever asks.

How should you confirm location at each visit?

1. Ask at the start of every session and record the answer in the note, including the state.
2. Build the question into your scheduling or check-in flow, not just your memory.
3. Tell clients at intake that you can see them only from states where you are authorized, and ask them to tell you before they travel.
4. Keep a current list of states where you are licensed, certified or registered, and the states where nothing is required.
5. If a client turns up somewhere you are not authorized, reschedule rather than proceed.

Our sister site covers patient location verification in more depth for telehealth programs generally.

Which states let you see a client without any local credential?

Those that issue no dietitian credential: California, Colorado, Virginia and Arizona, plus Michigan and New Jersey while their regulations are not in effect. Texas also lets you practice without its license as long as you do not use the "licensed dietitian" or "LD" title, and New York certifies titles rather than licensing practice. Watch titles in these states. California, Colorado and Virginia restrict who may call themselves a dietitian, and Virginia's statute names CDR registration and a license from another state among the qualifications for using the title (Va. Code § 54.1-2731).

Payers are separate. Medicare requires a license or certification in the state where services are performed, falling back on CDR registration only in states that do not provide for licensure or certification (42 CFR 410.134). See Medicare MNT and licensure.

How do you turn client locations into a license plan?

Pull a year of session data, count sessions by client state, and sort each state into required, title-only, registration available, or nothing required. That list is your plan. Our post on telehealth dietitian licensing walks through each category, and the state license index shows each state's rules.

We can do the sorting and the paperwork. A Readiness Review ($149) maps your client states. We then prepare each registration ($299 per state) or license ($599 by endorsement, $749 for a full application) and track it; you review, sign, pay the board and submit.