Thoughts from a broken mind
Deep within the annals of obscure amendments to state licensure statutes, and within the US Patent and Trademark Office’s records, a battle is raging which could have a massive impact on the way you access nutrition information in our nation’s healthcare system.
Here’s the outline:
Through a series of bills it is supporting and lobbying for, the nation’s professional association of dietitians, the Academy of Nutrition and Dietetics—generally known to the public by its old name, the American Dietetic Association—appears to be gaining legal control over who may provide nutrition counseling in a professional context. The effort also extends through a series of certification trademarks for which the Academy has recently applied.
This past January, the group, founded in 1917 and known for almost a century as the American Dietetic Association, announced it was changing its name to the Academy of Nutrition and Dietetics. (I use the old and new name equivalently in this article.)
Last December, before it announced its name change, the Association applied with the US Patent and Trademark Office for a series of certification marks, a type of trademark related to credentialing, for a comprehensive array of nutrition-related professional titles, including:
The certification mark applications, in conjunction with the name change, suggest that the Academy is attempting to expand its scope and influence, from its decades-old role as the industry group for Registered Dietitians (RDs, who often work in institutional settings such as schools and hospitals), to now touch upon the entire field and professional practice of nutrition.
Indeed, an internal American Dietetic Association document, entitled “Regulatory and Competitive Environment of Dietetic Services,” appears to imply a strategy for gaining legal control over the term “nutritionist,” as a path to limit competition for its members, against competing types of nutrition counseling.
[UPDATE 4/9/12: A reader alerted me that the link above, which originally led to a copy of the document posted on the Washington State Academy of Nutrition and Dietetics website, stopped working days after my article came out, and now returns a Page Not Found notice. I am working on a follow-up article to determine why the Washington State AND took the document down after my article generated press attention and public discussion about it.]
[UPDATE 4/10/12: Yesterday I sent representatives from the national office of the Academy the following email:
I find it quite a coincidence that this happened to be taken down days after the first major media coverage of the document.
I have a few questions for your comment:
Did you or anyone in the national AND office issue any directive to take that document down?
If so, why did you want the document taken down?
If not, who was responsible for taking it down, and why did *they* want the document taken down?
If the reasons for the document being unavailable are merely technical (server overload, etc.) would you be willing to ensure that the document gets reposted, so full public discussion of the document may continue?
I sent a similar email to the Washington State chapter of the Academy. Today I received an email from the executive director of the Washington State chapter, informing me that the document has been restored. Thank you, Washington State AND, for restoring it. No comment yet on any of my questions, from either the national or Washington State chapter. I'll let readers speculate as to why it might have been taken down after my article was published.]
While no one would deny that Registered Dietitians often provide extremely valuable nutrition services across a wide range of settings (in schools, hospitals, and corporate workplaces, to name a few typical places), this article is not about Registered Dietitians per se.
Rather, I focus here on the professional association that represents them politically, and particularly, on its apparent efforts to protect RDs against marketplace competition from other nutrition professionals. The article raises the question: should consumers have access to a wide array of different nutrition counseling choices/philosophies, among a wide array of professionals with differing credentials, or should the American Dietetics Association have strong legally-enforced say in who may or may not compete with the specific group of nutrition professionals it represents?
The American Dietetic Association’s Anti-Competition Document
The Association document linked above minces no words about its purpose. It opens: “This Backgrounder highlights the significant competitive threat Registered Dietitians. . . face in the provision of various dietetic and nutrition services. . . . We must be aware that existing legal and regulatory constraints on practice are unlikely to prevent robust, broad competition in these growth areas.” [Emphasis added.]
The document specifically bemoans that the word “dietitian” (the professional association’s decades-old area of coverage and speciality) is regulated far more heavily than the word “nutritionist”:
Simply put, governments more strictly regulate the work of and qualifications for dietitians than it does for nutritionists, and competitors are explicit about their intention to exploit this dietetics/nutrition distinction. An array of competitors is already providing would-be clients with personalized health education and nutritional counseling in growth areas such as prevention and wellness and in private practice careers. The required and necessary skill set of RDs competing with these other nutrition professionals may not necessarily be the same that clinical dietitians [sic], but RDs cannot cede this expanding market to others who clearly intend to provide nutrition services. [Emphasis added]
The document goes on to survey in detail the competitive threat posed by many different types of non-RD practitioners who give nutrition advice:
Finally, the Academy seems to outline a strategy to prevent the competition: gain legislative control over the term nutritionist: “A troubling pattern exists when looking at practice exclusivity and title protection in the most populous states, particularly with regard to non-licensed practitioners’ use of the title ‘Nutritionist.’ None of the three states largest in population protect the title ‘Nutritionist.’”
While there is no known link [see UPDATE below for an explicit link] between this specific document and the Academy of Nutrition and Dietetics’ legislative and lobbying activities, the Academy is indeed lobbying for a series of bills in states across the nation, which appear to be broadly consistent with the Academy’s aim—published in the document cited above—of protecting Registered Dietitians from free competition with other nutrition professionals.
[UPDATE 4/11/12: A reader pointed out to me something I hadn't noticed: The document in question states, at the bottom of page 1, that it was authored by one "Pepin Andrew Tuma, JD," then of the consultancy "Tuma Strategies." Now the Director of Regulatory Affairs for the Academy. In other words, via Tuma there is a clear, direct link between the anti-competition document quoted earlier in this article, and the legislative efforts Tuma himself is now spearheading as Director of Regulatory Affairs for the Academy.]
The bills define a licensed profession called “dietetics and nutrition,” or “dietitian nutritionist” [emphasis added] and provide stiff penalties—in some cases 6 months of jail time, or in other cases $10,000 per day of violation—to anyone who practices the nutritionist profession without a license.
The licensure bills vary state-by-state, but Illinois SB2936, the “Dietitian Nutritionist Practice Act,” an amendment to and extension of an already-existing licensure law, facing vote soon, is typical. The bill states that “Any person who practices, offers to practice, or holds oneself out as being able to provide dietetics and nutrition services without being licensed under this Act shall. . . pay a civil penalty to the Department [of Financial and Professional Regulation] in an amount not to exceed $10,000.” Similar bills in other states include sanctions of up to six months in prison.
The “nutrition services” defined include any form of “nutrition counseling.”
What are the requirements for being licensed by the state under these bills to provide nutrition counseling? Essentially, the same requirements as those for the Registered Dietitian credential.
Though the laws do not actually require you to be a Registered Dietitian to receive a license, the requirements are substantially similar to those created by the ADA for Registered Dietitians.
Specifically, in order to become licensed by the state to provide nutrition counseling, practitioners must pass an exam which “may be or may include an examination given by the Commission on Dietetic Registration.”
The Commission on Dietetic Registation is the American Dietetic Association’s credentialing agency.
Other requirements are equally dietitian-oriented. In order to be licensed, practitioners must also complete a “dietetic internship. . . of not less than 1,200 hours under the supervision of a registered dietitian or a licensed dietitian nutritionist.” A requirement of the American Dietetic Association to be accredited as a Registered Dietitian is a dietetic internship of 1,200 hours.
Next: Is the Academy of Nutrition and Dietetics Attempting to Create a Monopoly in Nutrition Counseling?
Pepin Tuma, Director of Regulatory Affairs for the Academy, told me that the purpose of these laws is to protect the public. “When the public seeks out evidence-based, scientific nutrition information, it’s critically important that that’s what they’re actually getting. Licensure allows people to be certain that the person they’re going to has the competency to be able to help them and not hurt them. Harm from incompetent practitioners comes in a variety of forms, both physical and financial.”
The Academy strongly denies that it intends to limit the ability of other recognized nutrition professionals to practice their profession through these laws. Tuma was emphatic to me on this point. He emphasized that the intention of the bills is to regulate only those forms of nutrition counseling and therapy which are done in a medical context, such as supporting the treatment of medically diagnosed diseases:
“Certain nutrition questions on medical nutrition therapy, concerning the interplay between disease states and nutrition, really do require a higher level of evidence-based practice and experience and competency. Licensing of dietitians and nutritionists is not intended to restrict the provision of general non-medical nutrition. That’s something that we’ve been very careful to include in both laws and exemptions. Nutrition is such a critical issue now in this country, there’s a role for many different groups to play.”
Tuma continued, “If you’re an acupuncturist, for example, in many states you have to be licensed. And if an acupuncturist providing nutrition information is acting within her own scope of practice, she will not run afoul of a licensing law that may appear to be very broad and restrictive, but actually has exemptions to ensure that anybody who is practicing their profession within their licensed scope of practice is able to continue doing that.”
Critics contend, however, that this “scope of practice” point is the devil in the detail. The Academy’s anti-competition document, cited above, strongly implies an intention to focus on scope of practice and practice exclusivity clauses as a way to limit competition:
Most of this above-described competition is perfectly legal. . . [as] states lack the authority to prevent the unlicensed practice of dietetics because the state (often consciously) neglected to include a practice exclusivity clause (providing that only individuals whom the state has properly licensed may engage in activities falling within the regulated profession’s scope of practice) in its dietetics practice act.
In other words, the Academy document states, the competition it bemoans is legal because those who are licensed as dietitians have not been grantedexclusive domain to practice nutrition.
The newly-proposed bills tend to change this, and tend include the very practice exclusivity clause called for in the Academy document: only those practitioners who have passed the Academy-approved exam, and who have completed the 1,200-hour dietitian internship, and who have received the license, may provide nutrition counseling.
The bills do tend to include exemptions which state that they are not designed to prohibit or restrict “Any person licensed in this State under any other Act from engaging in the practice for which he or she is licensed.”
That, says Darrell Rogers, Communications Director of the Alliance for Natural Health, is the kicker. “If nutrition is within the practitioner’s recognized scope of practice within that state, then these bills would not affect them. But in many states, personal trainers, health coaches, and even Ph.D. nutritionists, either don’t have a scope of practice, or if they do have a scope of practice, nutrition might not be within it. So all those individuals would be subject to the charge that they are practicing dietetics and nutrition without a licence.”
Thus, if your yoga instructor or personal trainer or acupuncturist did not have a legally-defined scope of practice for nutrition counseling in your state, and your instructor/trainer/acupuncturist, etc., advised you in what kind of diet to eat in conjunction with your workout or healing program, she could be criminally charged under these bills for practicing dietetics and nutrition without a license.
Diane Miller, Legal and Public Policy Director of the National Health Freedom Coalition, told me: “The thing that a group promoting an exclusive licensure bill always says to legislators, at the state capitol, is ‘This isn’t going to hurt anyone else. This is no big deal. We just want our licensure because we want to get insurance coverage,’ etc. That’s what they say politically in their lobbying efforts. But when you read the language of the bills, it’s the exact opposite.”
Dietitian licensure laws have been used in other states to deny practice to highly educated nutrition practitioners who don’t happen to have a Registered Dietitian designation, effectively limiting dietitians’ competition in those states.
For example, Liz Lipski, who has a Ph.D. in clinical nutrition and an MS in nutrition, but who does not have a Registered Dietician credential, was told last year by the North Carolina Board of Dietetics/Nutrition that she could not practice nutrition in that state.
Specifically, Lipski says on a site detailing her case, she was asked to return to college and take several semesters worth of undergraduate courses common for those studying to be Registered Dietitians, but which were not on her program of study as a nutritionist. Rather than return to the undergraduate level as a Ph.D., she sold her home, uprooted herself and her family and took her practice to Virginia. Lipski writes on her site:
In about 35 states, qualified nutritionists are being denied their right to practice because of restrictive laws. These laws were written by dietitians, for dietitians, and in many cases administered by dietitians. These laws limit the public’s right to choose the type of nutritionist they want to see and restrain trade. They also deny right to livelihood to people who are well-trained in the field of nutrition.
In 2009 in Ohio, Jessica Stamm, who has a MA in Human Nutrition but not an RD certification, received a letter from the Ohio state government telling her to shut down her nutrition practice immediately. She moved to Hawaii, and was soon facing a similar prospect through Hawaii’s HB 2570 bill.
Here is a video detailing Stamm’s story [the Hawaii bill referenced has since been defeated]:
Jim Turner, chair of the board of Citizens for Health, and a veteran of state regulatory fights against ADA-supported licensure laws, told me: “What’s fascinating about this situation is that the ADA structure actually excludes some of the most nutrition-educated people in the country from being able to provide nutrition information. You can have a master’s in nutrition or even a Ph.D. and not qualify for the ADA recognition. So you have people who are well-qualified in nutrition, who are not allowed to exchange that information with consumers, because they don’t have a legally recognized scope of practice. That’s a tragic, unfortunate result of these laws.”
Stories such as Lipski’s and Stamm’s, in conjunction with the anti-competition document cited above, have led to organizations like the Alliance for Natural Health to charge that the main purpose of the dietitian laws is not to protect public health, but rather to promote the ADA’s agenda. The ANH describes this agenda as a “Race for Monopoly,” effectively restricted to dietitians, and/or to those who have gone through what substantially amounts to the dietitian program of study.
In response to the licensure laws, the ANH has created a site calledReallyEatRight.org, which states:
The practice of dietetics is one of the many different modalities of nutritional therapy. Dietitians—and particularly the Commission on Dietetic Registration—should respect and compete with other nutrition professions and licensing bodies in the marketplace, and should not subvert competition by creating a government-sanctioned monopoly through legislation.
Rogers of the Alliance for Natural Health told me, “More and more people and professions are seeing that nutrition is the best way to maintain good health, and even treat disease. The American Dietetic Association sees this as a huge economic growth area. They want to make sure that they monopolize as much of that as possible.”
Next: Can There Be Common Ground?
It does appear, despite the heat of the debate, that there is common ground between the opposing sides, around the concept of title protection.
That is, even some critics of the American Dietetic Association support robust legal enforcement for the title “Registered Dietitian,” meaning only those who actually have that credential can call themselves such—so long as those who don’t even claim to be RDs can still practice their trade.
Rogers told me: “We’re generally supportive of titling bills, because we think it helps consumers to know the difference between these different professions. But there’s a big difference between a law that says you have to pass X, Y, and Z tests and have X, Y and Z educational background to call yourself a dietitian—versus a law that says, only dietitians can practice anything having to do with nutrition, and everyone else is now violating the law.”
Jim Turner of Citizens for Health told me he was supportive of laws requiring practitioners to be clear and honest about their educational background in nutrition: “From the consumer point of view, we don’t believe someone needs to have a state-defined scope of practice to provide nutrition counseling. What practitioners need is educational background, and they then make that known to the consumer. We believe the proper way to procede should be this: nutrition practitioners should lay out exactly what their educational background is. If you misrepresent your educational background, then you’re subject to legal sanctions for misrepresentation. However, the idea of creating a scope of practice for nutrition information is anathema to the consumer interest.”
Join the Debate
Few Americans would support legislation specifically designed to reduce marketplace choices and restrict open, fair competition, if indeed that is the purpose of many of the bills (as critics contend, and the document above seems to imply.)
And yet, the public clearly has an interest in knowing that, when someone claims they have an educational background and training in a health field, they do in fact have that background and training.
Is it enough for you to know—through a legally protected professional title—that a Registered Dietitian has a certain level of educational training, which other nutrition counselors don’t have?
Or should you be prevented altogether, as certain stakeholders believe will happen, from accessing nutritional counseling from personal trainers, yoga instructors, chiropractors, acupuncturists, nurses, pharmacists, and even Ph.D. nutritionists, who may not have a specific scope of practice in nutrition in your state, as defined and recognized by government regulators?
In sum, should the government be the arbiter of what constitutes sound nutrition advice?
Join the debate below—let me know your thoughts on this important issue in the comments section.
UPDATE 4/10/12: The day I published my article, Pepin Tuma, Director of Regulatory Affairs for the Academy, sent me an enraged email:
Just finished reading the article, and am shocked how many demonstrably false conclusions you make and quotes you included. I had hoped the article would be honest (or that you would come back to me so I could refute the lies your article contains), but you chose not to.
Please expect a detailed refutation by tomorrow, and I look forward to discussing the process by which you will correct your embarrassing mistakes.
Minutes after sending this one, he dashed off a follow-up email:
You also may want to run a spell-check on your article
The “detailed refutation” he sent the next day consisted of a PDF letter addressed to me and requesting a response from me, taking exception with just two quotes from my article, just 113 words out of a 3,245-word article. (He did not, unfortunately, send me any spelling corrections, so I leave it to you, dear readers, to point any out.)
He sent his refutation letter to me at 6:09PM last Friday evening. I planned to respond the following workday. But before I could respond, at 11AM that Monday, he forwarded the same refutation letter addressed to me, to Steve Forbes.
Yes, you read that correctly. Before I even had time to answer his letter addressed to me, a copy of the same letter was on the desk of the Chief Executive Officer of Forbes, Inc., the man whose name I hope I do proud with my own investigative journalism.
Tuma’s email to Mr. Forbes complained of “egregious factual inaccuracies” in my article, requested that Mr. Forbes please “review the letter [sent to me only a few work-hours before] and consider an appropriate response from Forbes [magazine],” and stated that “it is very important for your readers to be armed with the facts rather than Mr. Ellsberg’s opinion and misstatements.”
Wait, was it me who was supposed to answer Tuma’s letter addressed to me, or was it Mr. Forbes?
(It all reminded me of some vaguely-recollected incident of from my childhood, when a kid challenged me to a fight after school for insulting him, but before I could accept the fight, he had his mommy call my mommy to complain about me.)
Again before I could respond, at 1PM Monday, another copy of the letter sent to me requesting my response, and then sent to Mr. Forbes requesting his response, was–bizarrely–posted on the website of Food Managementmagazine, of all places–a publication which “provides ideas for foodservice directors, managers and chefs through coverage of industry issues and events, operational topics and food trends that affect the noncommercial foodservice industry.” The post reprinting the letter addressed to me was entitled “ADA Responds to Forbes.”
I later dug around, trying to figure out how the letter addressed/sent to me ended up in a trade journal only a few workday-hours after I had received it. It appears the House of Delegates (the governing body which originally initiated the creation of the anti-competition document), sent Tuma’s response around the dietitian world:
As you may already be aware, an article was published on Forbes.com on Thursday, April 5, 2012 addressing the Academy’s licensure efforts. Pepin Tuma, director of regulatory affairs, was interviewed by the author and is quoted in the article. The article references CDR’s Competition Study document, which outlines the structure and importance of our efforts. This document was intended for internal purposes only. [Emphasis added]
On Friday, April 6, the Academy responded to the article published in Forbes.com on April 5. The response to the author, Michael Ellsberg, is attached; [emphasis added] also, the response was also sent to the editor of Forbes.
HOD Governance Team
A copy of the PDF letter was also quickly posted on this ADA House of Delegates site–all of which suggests the letter was more about publicly covering bureaucratic behinds, rather than actually soliciting a response from me.
Anyhow, let’s look at the “lies,” “embarrassing mistakes,” “egregious factual inaccuracies,” and “misstatements” Tuma accuses me of in his bluster and chest-puffing in advance of his “detailed refutation.” Here is the answer I finally did email to Tuma, at 2:40pM Eastern yesterday (after Mr. Forbes and the readers of Food Service Magazine and all the recipients of the House of Delegates memo had already had a crack at answering the letter for me.)
You cite two quotes of mine which you find inaccurate:
1. “Thus, if your yoga instructor or personal trainer or acupuncturist did not have a recognized scope of practice for nutrition counseling in your state, and your instructor/trainer/acupuncturist, etc., advised you in what kind of diet to eat in conjunction with your workout or healing program, she could be criminally charged under these bills for practicing dietetics and nutrition without a license.”
2. “Or should you be prevented altogether, as certain stakeholders believe will happen, from accessing nutritional counseling from personal trainers, yoga instructors, chiropractors, acupuncturists, nurses, pharmacists, and even Ph.D. nutritionists, who may not have a specific scope of practice in nutrition in your state, as defined and recognized by government regulators?”
In response to these two paragraphs, you state: “Licensure laws are drafted to ensure that anyone—yoga teachers or personal trainers—can provide general non-medical nutrition information.”
Yet in both my paragraphs above it is either stated explicitly (quote 2) or strongly implied from the context of the article (quote 1) that what I am talking about is “competitor professions,” as your document refers to them, providing nutritional counseling (as in 1-on-1, back-and forth professional practice with a paying individual client), NOTproviding general “nutrition information.”
I understand there are exemptions for dissemination of nutrition information. Of course there are. This nation has a first amendment protecting free dissemination of information (My father, for example, has tested the first amendment’s protection of disseminating information about as far as it can be tested, quite successfully.)
I’m not talking about disseminating nutrition information, I’m talking about practicing nutrition counseling i.e., practicing nutrition with clients. (I suppose quote 1 above could arguably be more definitive on that point, and I’m happy to revise it to use the term “nutrition counseling” if necessary, to be absolutely beyond-a-shadow-of-a-doubt clear that I’m talking specifically about counseling, not information.)
In my article, you provided the quote, “And if an acupuncturist providing nutrition information is acting within her own scope of practice, she will not run afoul of a licensing law that may appear to be very broad and restrictive, but actually has exemptions to ensure that anybody who is practicing their profession within their licensed scope of practice is able to continue doing that.”
Yet, as the ADA’s critics quoted in my article state, many competitor professions such as chiropractors, acupuncturists, and non-RD nutritionists, routinely provide nutrition counseling (not information but counseling), yet may not yet have gone through the same lobbying your organization has done, and thus may not yet have nutrition counseling legally specified in their scope of practice [or, I might add, might not yet have a legally-defined scope of practice, since they may not have lobbied for one yet.]
The Illinois law states that it does not apply to “Any person licensed in this State under any other Act from engaging in the practice for which he or she is licensed.” Which means, if the nutrition professional did NOT have a legally-defined scope of practice (as many, many alternative health providers, and even nutritionists with MAs and even PhDs do not), your Model Practice Act is clear as day that this would constitute practicing dietetics and nutrition without a license, and thus would shut down these forms of competition.
Indeed, that is the very thing it is designed to do, so far as I can tell: prevent people who don’t yet have a legally-defined scope of practice in nutrition in their state, and who haven’t jumped through the very dietitian-oriented licensure requirements you propose, from practicing nutrition counseling in that state.
Which means that many chiropractors, acupuncturists, and even PhD nutritionists and other competitor professions–many of whom routinely offer nutritional counseling as part of their program–could be charged with practicing dietetics and nutrition without a license,if they haven’t yet proactively created for themselves a scope of practice for nutrition counseling in that state.
You write that “In fact, there is not a single dietetics licensure law in the country that would prohibit licensed chiropractors, pharmacists, nurses, personal trainers, or acupuncturists from providing nutritional counseling.”
The Illinois bill and others I have read make it clear that competitor professions *would* be prohibited from providing nutrition counseling, if nutrition counseling was not already in their recognized scope of practice.
So wouldn’t it be more accurate to add ”…if nutritional counseling is within their recognized scope of practice” at the end of your sentence above? Without adding that extra bit, your sentence above is entirely inaccurate and false. And if that extra phrase is so added, then everything I’ve stated in my article is consistent with your statement.
Finally, you write “Licensing of dietitians and nutritionists is not intended to restrict the provision of general non-medical nutrition information.”
I understand that. My article is about attempts to prohibit what you call “competitor professions,” such as non-RD nutritionists, from practicing nutritional counseling, the very activity that your bills propose to regulate. No one is debating that your proposed laws take away people’s first-amendment rights to disseminate information. What we’re talking about is other professions’ ability to practice nutrition counseling.
Unless you can confirm on the record, and show me relevant clauses in the state laws, that you intend to fully protect the ability to provide nutrition counseling (not information but counseling) of acupuncturists, yoga instructors, PhD nutritionists’, and other competitors who don’t have an already- recognized scope of practice for nutrition in that state, then the quotes you object to seem perfectly accurate to me and I stand by them.
No response yet. I’ll keep you updated if I get one.
It did occur to me: Tuma’s refutation letter to me is craftily-worded, reflecting brilliant lawyering skills to obfuscate the issue.
It trades on a verbal sleight-of-hand–pointing to the ADA’s support for the free dissemination of “nutrition information”–to attempt to distract my (and your) attention from the reality that the bills are extremely harsh on those who would practice nutrition counseling if they haven’t yet proactively sought-out a legally-recognized scope-of-practice to do so.
Given this elaborate slight of hand, I wondered: Why doesn’t the ADA just come out and say it? Why don’t they just say: “Yes, that’s right. We’re trying to prevent acupuncturists, physical trainers, yoga instructors, personal trainers, chiropractors, and non-RD nutritionists, from practicing nutrition counseling, if they don’t yet have scope of practice to do so (or if they don’t have a professional scope of practice at all.) Because we believe that the training RDs get is superior. And, we believe that, so much as possible, the public should only receive nutrition counseling from professionals who have gone through what substantially amounts to the RD program of study, including our exams and our internship.”
I still wouldn’t agree with that position. But at least I would respect that it was an openly-stated, straightforward position. Unlike the skillfully-crafted Clinton-esque lawerly sleight-of-hand of Tuma’s “refutation,” which was clearly intended to obfuscate and distract from the real intentions of the ADA.
In the meantime, I might add:
If Tuma’s response amounted to a “detailed refutation” of my article, and if the two quotes he objects to in his refutation amount to “lies,” ”embarrassing mistakes,” and “egregious factual inaccuracies,” requiring the urgent attention and review of Mr. Steve Forbes himself…
…then the ADA is a freedom-loving organization which deeply respects the right of American consumers to choose nutrition counseling from whichever practitioner they please, even if the practitioner is not a Registered Dietitian.
See if there is new updates at: www.forbes.com/sites/michaelellsberg/2012/04/05/american-dietetic-association/