Medicare Part B Coverage and MNT Billing Guidelines


Marie Infante, JD, MBA, MS; special counsel, Mintz, Levin, Cohn, Ferris, Glvosky, and Popeo and Pam Michael, MBA, RD, Director, ADA Health Care Financing Team

J Am Diet Assoc, January 2002, Vol. 102  No.1, Page 32.


Current Procedural Terminology (CPT) codes and billing procedures for Medical Nutrition Therapy (MNT) services within government funded programs and private sector insurance plans have varied and been widely interpreted by carriers and billing agencies. The interpretation and regulations for billing Medicare Part B for MNT services has become clear as a result of legislation and regulations established respectively by Congress and the Centers for Medicare & Medicaid Services (CMS). This article provides members with specific guidelines for billing Medicare Part B for current and future MNT services. Billing procedures for private insurance companies or Medicaid are not discussed in this article.

Medicare Part B billing procedures for certain diseases are defined as a result of the Medicare, Medicaid and SCHIP Benefits Improvement and Protection Act (BIPA) of 2000. Section 105 of BIPA, amended section 1861 (s) (2) of the Act authorized Medicare Part B coverage of "nutrition services for certain beneficiaries who have diabetes or kidney disease, effective for services furnished on or after January 1, 2002". (1) CMS is the agency responsible for determining the regulations for providing nutrition services within the Medicare MNT benefit. CMS has indicated "Medicare will pay qualified dietitians and nutrition professionals who enroll in the Medicare program regardless of whether they provide medical nutrition therapy services in an independent practice setting, hospital outpatient department or any other setting with the exception of services provided to patients in an inpatient stay in a hospital or skilled nursing facility." (1)

In addition to details defined in the Medicare MNT benefit regulations, ADA also commissioned senior legal advisor Marie Infante, JD, MBA, MS, BSN, who specializes in Medicare policy and practices at the firm Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, to assess policies regarding Medicare Part B reimbursement for medical nutrition therapy (MNT). This ADA member guide is compiled to assist members in providing MNT in accordance with Medicare compliance guidelines. For additional resources on Medicare Part B compliance, provider information, and communicating with compliance officers/billing department staff,  visit ADA's member-only Web pages by clicking the "Policy Initiatives & Advocacy" main tab and the "Medical Nutrition Therapy" left-hand side bar. 
Medicare Part B Billing Guidelines  

  • The Centers for Medicare and Medicaid Services (CMS) recently confirmed RDs should not bill Medicare Part B for medical nutrition therapy for any diagnosis. Only after the Medicare MNT benefit is effective, January 1, 2002, can RDs bill Medicare Part B for MNT for diabetes and kidney diseases. 


  • RDs or the facilities where they are employed cannot bill Medicare Part B for medical nutrition therapy (MNT) prior to January 1, 2002.


  • Effective January 1, 2002, RDs and nutrition professionals will be able to bill Medicare Part B for MNT for diabetes and kidney disease. (1) RDs cannot bill Medicare Part B for MNT prior to 2002.

    CMS defines "renal disease" as chronic renal insufficiency and post-transplant care provided after discharge from the hospital (1), and refers to the Institute of Medicine (IOM) definitions cited in The Role of Nutrition in Maintaining Health in the Nation's Elderly (2) for further definitions of the two diseases. IOM defines chronic renal insufficiency as the stage of renal disease associated with a reduction in renal function not severe enough to require dialysis or transplantation (glomerular filtration rate 13-50 ml/min/1.73m2). Diabetes mellitus type 1 is defined as an autoimmune disease that destroys the beta cells of the pancreas leading to insulin deficiency. Diabetes mellitus type 2 is defined as a familial hyperglycemia that occurs primarily in adults…, caused by an insulin resistance whose etiology is multiple and not totally understood. IOM lists the diagnostic criterion for a diagnosis of diabetes as a fasting glucose tolerance test > 126 mg/dL.
  • RDs cannot bill Medicare Part B for MNT as 'incident to' physicians' services. (1) This applies to all diagnosis, including diabetes and kidney disease.
  • RDs who would like to bill Medicare beneficiaries for MNT for other diseases besides diabetes and kidney disease as defined within the Medicare MNT benefit, can only bill the patient/client for the service.
    The patient would pay out-of pocket for the MNT services. Medicare Part B cannot be billed for MNT provided for other diseases besides diabetes and kidney diseases (benefit effective Jan. 1, 2002).
  • Prior to January 2002, an Advanced Beneficiary Notice (ABN) is not required since MNT services are not a covered Medicare benefit. Once the Medicare MNT benefit is effective, Jan. 1, 2002, an ABN should be used for Medicare beneficiaries with diabetes or kidney disease, who receive MNT from an RD. After Jan. 1, 2002, if MNT is provided to Medicare beneficiaries with other diagnosis, not diabetes or kidney diseases, Medicare should not be billed and an Advance Beneficiary Notice is not required since other diagnosis are not covered by Medicare Part B.
Next Steps for Medicare Part B MNT billing

  • Review current MNT billing practices for outpatient settings.  
  • Consider billing adjustments as indicated.

1. Federal Register, 42 CFR, Part 405 et al, Vol. 66, No. 212, November 1, 2001; Medicare Program; Revisions to Payment Policies and Five-Year Review of and Adjustments to the Relative Values Units Under the Physician Fee Schedule for Calendar Year 2002: Final Rule, pages 55275-55281.

2. The Role of Nutrition in Maintaining Health in the Nation's Elderly, Institute of Medicine, National Academy of Sciences, 2000, pages 118 and 133.