How is “practice” defined?

The Board’s office is frequently contacted by practitioners, and by members of the public, who want to know what constitutes “practising”. The caller may be a registered dietitian who is semi-retired and considering “just working an hour a week as a nutritionist”, or a member of the public who saw an ad on the internet promoting “nutritional advice” – only to discover that the practitioner involved doesn’t hold a current practising certificate.

Practise as defined in the HPCA Act means to perform services that fall within the description of the profession (refer section 5 – Interpretation). In accordance with section 11 of the Act the Board describes the Scope of Practice: Dietitian (from 1 April 2017) as:

Dietitians are registered health practitioners who evaluate scientific evidence about food and nutrition and translate it into practical strategies. Dietitians work in partnership with individuals, whānau, communities and populations, in states of health and disease, to support optimal health and well-being.

Dietitians use their dietetic knowledge, skills, and judgement in a variety of contexts, which includes promoting and protecting public health, directing and delivering medical nutrition therapy services, and managing food and health systems. They may perform a variety of functions, including policy development, leadership, management, research, education, and communication roles.

Dietitians with a prescribing endorsement are able to prescribe Special Foods and approved nutrition-related medicines.

Dietitians are accountable for ensuring that their practice is consistent with the Dietitians Board’s competency requirements, Code of Ethics and Conduct, and relevant legislation.

This is a very broad description, and one which likely overlaps with many activities performed under titles such as nutritionist, food service manager, policy advisor, health activator, lifestyle coach, health promoter. Further, there is no limitation under the Act that these services be performed for remuneration or in the context of a clinical relationship or otherwise (e.g., management, administration, education, or research). Practitioners therefore must be aware that, as long as they remain on the Register of Dietitians, they must hold a current practising certificate if they practise (under any title) within the scope of dietetics (as described by the Board).

Unfortunately, the Board are hearing more often of practitioners on the Register who are practising in such areas without holding a practising certificate. We are obliged to make enquiries where such cases come to our attention. The penalties under the Act for practising without a current practising certificate can be very severe, which reflects just how important the practising certificate regime is as a mechanism to ensure that dietitians are competent and fit to practise the profession.

We strongly recommend that all practitioners who are currently on the Register but who don’t hold a practising certificate review their circumstances carefully in light of the information above, and then formally notify the Board if they a) require a practising certificate, b) are not practising but wish to remain on the Register, or c) wish to come off the Register. Far better that we hear from you before we hear from a concerned member of the public.