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Nutrition CARE Act of 2025 adds Medicare coverage for medical nutrition therapy for eating disorders

Establishes Medicare coverage for medical nutrition therapy for eating disorders, sets provider and referral rules, and prescribes annual service limits beginning January 1, 2026.

The Brief

The Nutrition CARE Act of 2025 amends Title XVIII of the Social Security Act to require Medicare coverage of medical nutrition therapy (MNT) services for beneficiaries diagnosed with eating disorders. The amendment inserts eating disorders (defined by the DSM) into existing Medicare MNT authorities and creates service, provider, and referral parameters for those services.

This matters because Medicare has historically paid for some components of eating-disorder care but excluded outpatient nutrition therapy at scale; the bill targets that gap by authorizing MNT under Medicare and prescribing how those services will be delivered and billed. Compliance officers, billing managers, and clinical program leads will need to prepare for new coverage rules, provider credentialing questions, and documentation standards once the change takes effect January 1, 2026.

At a Glance

What It Does

The bill adds 'eating disorder' (to be defined by the DSM) to the list of conditions eligible for Medicare medical nutrition therapy and amends existing statutory MNT language. It specifies that MNT for eating disorders must be furnished by a registered dietitian or a 'nutrition professional,' require a referral from a physician or psychologist/authorized mental health professional, and sets annual hour limits for services.

Who It Affects

Medicare beneficiaries with eating disorders and the clinicians who treat them—particularly registered dietitians and other nutrition professionals—will be directly affected. CMS and Medicare administrative contractors will need to incorporate new benefit rules; hospitals, outpatient clinics, and behavioral health programs that coordinate nutrition care will see operational impacts.

Why It Matters

The change closes a coverage gap for a treatment component that clinical guidelines identify as a core element of eating-disorder care, but it does so through statutory service limits and referral rules that will shape access, billing, and program design. The provision creates predictable benefit parameters while leaving several implementation choices to CMS.

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What This Bill Actually Does

The bill inserts eating disorders into Medicare’s statutory medical nutrition therapy framework by amending section 1861 of the Social Security Act. Instead of creating a standalone benefit, it folds eating-disorder MNT into existing MNT language: the condition must be defined according to the most recent Diagnostic and Statistical Manual of Mental Disorders, and coverage begins January 1, 2026.

That definition will be central to eligibility determinations and claims adjudication.

On the delivery side, the statute limits who can furnish reimbursable services: a registered dietitian or a statutory 'nutrition professional.' The services must follow a referral by a physician or by a psychologist (or other mental health professional to the extent state law permits). This referral requirement ties MNT for eating disorders to medical or behavioral health oversight, which affects how practices organize intake and interdisciplinary coordination.The bill establishes quantity limits: an initial 1-hour assessment plus 12 additional hours of reassessment and intervention in the first 12 months (13 hours total), and 4 hours in each subsequent 12-month period.

However, it gives the Secretary of Health and Human Services discretion to apply other reasonable limitations for subsequent years. Those numerical caps will define billing bundles, encounter documentation, and clinical workflows.Procedurally, CMS will need to adopt implementing guidance: define 'nutrition professional' if not already defined in regulation, create eligible ICD/diagnosis mappings using the DSM reference, issue billing codes or guidance for the new covered scenario, and determine whether telehealth modalities qualify.

Because the bill amends existing MNT sections rather than creating a separate benefit, CMS is likely to reuse existing Medicare Part B MNT payment and administrative processes, but will still face decisions about coverage policy, provider enrollment, and payment rates.

The Five Things You Need to Know

1

The bill becomes effective January 1, 2026: Medicare will cover medical nutrition therapy for beneficiaries with an eating disorder as defined by the DSM.

2

Covered MNT must be furnished by a registered dietitian or a 'nutrition professional' (as defined in statute/regulation) to be reimbursable under Medicare.

3

A referral is required: services must be provided pursuant to a physician referral or a referral from a psychologist or other mental health professional to the extent state law authorizes such referrals.

4

Service limits are statutory: 13 hours during the first 12 months (1-hour initial assessment plus 12 hours of reassessment/intervention) and 4 hours in each subsequent 12-month period, with Secretary discretion to set other reasonable limits.

5

The bill amends specific Medicare statutory sections (section 1861(s)(2)(V) and subsection (vv)) to integrate eating-disorder MNT into existing Medicare MNT and disease-management language.

Section-by-Section Breakdown

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Section 1

Short title

This section names the statute the "Nutrition CARE Act of 2025" or the "Nutrition Counseling Aiding Recovery for Eating Disorders Act of 2025." While ceremonial, it frames the bill’s intent and will be the reference title in subsequent rulemaking and guidance.

Section 3 — Amendment to 42 U.S.C. 1395x (section 1861)

Add eating disorders to MNT eligibility

The bill amends subsection (s)(2)(V) to add a clause that explicitly makes a beneficiary "with an eating disorder" eligible for MNT coverage, and ties the clinical definition to the most recent edition of the DSM. That linkage means CMS will rely on DSM criteria for claims adjudication and physician documentation supporting diagnosis, rather than creating a new federal diagnostic standard.

Section 3 — Modifications to subsection (vv)(1)

Provider and referral requirements

Changes to subsection (vv)(1) require that covered MNT services for eating disorders be furnished by a registered dietitian or 'nutrition professional' and only when provided pursuant to a referral by a physician or a psychologist/authorized mental health professional. Practically, this establishes who may bill Medicare and makes referral-source eligibility dependent in part on state scope-of-practice rules, a detail likely to cause variation in access across states.

1 more section
Section 3 — New paragraph (4) to subsection (vv)

Service hours and Secretary discretion

The bill creates paragraph (4) specifying minimum covered hours: 13 hours in the first year (a 1-hour initial assessment plus 12 hours of intervention/reassessment) and 4 hours in each subsequent year, while authorizing the Secretary to apply other reasonable limits for subsequent periods. This supplies a statutory floor for coverage while preserving administrative flexibility for CMS to adjust utilization controls or payment policies.

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Who Benefits and Who Bears the Cost

Every bill creates winners and losers. Here's who stands to gain and who bears the cost.

Who Benefits

  • Medicare beneficiaries with eating disorders — Gain statutory access to MNT services previously unavailable at scale under Medicare, which can improve integrated treatment planning and reduce out-of-pocket spending for nutrition care.
  • Registered dietitians and nutrition professionals — Obtain a clearer path to Medicare reimbursement for eating-disorder care, potentially expanding their referral base and practice revenue streams.
  • Behavioral health programs and multidisciplinary clinics — Can formally integrate reimbursable nutrition services into care pathways, improving continuity between medical, psychiatric, therapy, and nutrition pillars of treatment.

Who Bears the Cost

  • The Medicare program and Trust Funds — Covering additional MNT for a large beneficiary population will increase program expenditures and require CMS actuarial and budget adjustments.
  • CMS and Medicare administrative contractors — Must develop eligibility criteria, billing guidance, diagnostic mappings tied to the DSM, and potentially new claims edits and provider enrollment processes.
  • Providers and billing offices — Face new documentation, referral, and coding requirements; smaller practices may need to invest in compliance systems or partnerships to meet referral and documentation rules.

Key Issues

The Core Tension

The central dilemma is trade-off between expanding a narrowly targeted, evidence-backed service to improve clinical outcomes and imposing statutory caps and referral controls to limit federal spending and administrative complexity; the policy balances access and clinical adequacy against fiscal constraint and implementation practicality, with state scope-of-practice variability amplifying the risk of unequal access.

The bill solves a coverage gap but raises several practical implementation questions. Anchoring eligibility to the DSM gives CMS a clear diagnostic standard, but it may also force claims adjudicators to make nuanced diagnostic judgments that psychiatrists and clinicians normally manage in multi-disciplinary settings.

The statutory hour caps provide certainty for budgeting and benefit design but risk under-serving patients with severe or atypical presentations who commonly require more intensive nutrition engagement.

Other open issues include how CMS will define 'nutrition professional' for billing and enrollment, whether MNT provided via telehealth or group formats qualifies, and how the requirement for a referral from a psychologist interacts with varying state scope-of-practice laws. The Secretary’s authority to impose "other reasonable limitations" creates administrative flexibility but also uncertainty for providers trying to design services to fit likely future limits.

Finally, the law increases federal exposure to utilization growth among a large beneficiary cohort; the fiscal impacts will hinge on CMS rate-setting, utilization management, and whether Medicare Advantage plans change supplemental coverage in response.

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