I am starting a series this week, and I want to tell you what is in it before the first piece runs, so you can decide now whether it is worth your attention.
It is called On the Record. There will be eight pieces, and they are sequenced by when a door closes rather than by how much each subject matters to me.
That ordering is the whole idea, so let me explain it.
Why the order is the argument
Over the past year I have written a good deal about the pressures on clinical nutrition: the cost of entering the profession, the platforms that increasingly employ it, the payment system underneath it. Those pieces described problems. Several of them ended with some version of “and this is why it matters.”
The trouble with that ending is that it is not an instruction.
What changed my mind about how to write this was noticing that several of the things worth doing have published calendars, and that most of those calendars are further along than anyone in my profession seems to think. Federal comment periods close. Committee deadlines pass. Bills die at adjournment and start over. Legislatures convene in January and adjourn in spring.
A piece published after its deadline is an essay about something that used to be possible.
So this series is ordered by the clock. Here is the clock.
The dates
Every one of these was checked at the source that issues it during the last week of August and the first day of September.
14 September 2026 — Public comments close on the CY 2027 Medicare Physician Fee Schedule
30 September 2026 — A level-of-interest deadline at the committee that recommends what services are worth
October 2026 — Employer budget season
3 November 2026 — The election. Every committee assignment and contact list resets
December 2026 — Congress adjourns. Pending bills die and do not carry over
3 January 2027 — The new Congress convenes. Everything restarts from zero
January 2027 — Most state legislatures convene. Four states that sit only in odd years are among them
17 February 2027 — The next level-of-interest deadline
The first one is twelve days away.
The eight
Working titles. Some will change; the subjects will not.
No. 1 — Should Not Be Billed Separately. Tomorrow. Four provisions of one Medicare rule, read in the order they appear on the page, and what happens to a service when it stops being separately payable. It closes with the filing deadline, because that one is nearly here.
No. 2 — Ninety People. Before 30 September. How the value of a clinical service is actually decided, months before anyone sees a rate, by a survey most clinicians never hear about. This is the piece I did not know I needed to write until I read the calendar properly and found a deadline nobody had named.
No. 3 — Forty-Eight Dollars and Eight Cents. October. The case for a published national compensation benchmark for clinical dietitians, set against the credentialed peers they work beside rather than against where the profession has historically sat. It needs nobody’s permission, which is why it is in this series and not on someone’s agenda.
No. 4 — No Cost Estimate. November. Medicare’s nutrition benefit has a bill to expand it, and that bill has never been reported out of committee. The hardest question it faces is not clinical, it is the offset. I have a public answer to that question and I will make the case for it here, along with what happens when the bill dies in December and has to start again.
No. 5 — The Bill That Passed. November, while there is still time to act on it. State practice acts, the licensure compact, and a bill that cleared both chambers of one state legislature with bipartisan sponsors and was vetoed. A vetoed bill comes with a sponsor list, a fiscal note and a stated objection to answer, which is a much better starting position than a blank page.
No. 6 — Nobody Has Measured This. Early December. Repeated searches have not turned up a peer-reviewed study of what the graduate credential requirement did to the pipeline. Two neighboring professions have exactly that kind of evidence and have had it for years. This is the piece I think matters most, and it is this late in the order only because it has no deadline.
No. 7 — The Patients Are Not in the Plan. December. Every scope fight that has ever been won was won with patients in it. Almost everything I have written on this has been addressed to clinicians and policymakers. That is a gap in my own work and this is where I try to close it.
No. 8 — The Cost of the Credential. Only if it earns it. Federal borrowing caps, the professional-degree list, shortage-area loan repayment. I have written about parts of this before, and I will say now that if the honest version turns out to be an update rather than a new argument, I will publish it as an update and say so, or fold it into No. 6.
The shape, stated plainly
Seven of these run between now and mid-December. All of them are already written.
I had planned to publish four, stop for a couple of months, and finish in the spring. I changed that while I was checking the dates, and the reason is worth stating because it is the whole argument of this series turned back on itself.
No. 5 is about getting a bill in front of a state legislature. It says, in its own words, that a bill without a sponsor and draft text by the time a session opens is a bill for the following year. I had it scheduled for January — after most sessions convene. A piece published after its deadline is an essay about something that used to be possible, which is the sentence this series opens with. It now runs in November, while there is still time to do anything with it.
Nos. 6 and 7 have no deadline at all. Holding them until spring was about my capacity, not about the calendar, and since they are written there is nothing left to hold them for.
No. 8 is the one I will not promise a date for. It overlaps heavily with something I published in August, and it only runs if the honest version is a new argument rather than a repeat. If it is not, I will say so and fold what matters into No. 6. Seven pieces I can stand behind beats eight that include one written to fill a slot.
If a piece slips, I will say so in the next one.
One more thing, and it is the reason I am writing this at all
Alongside the series I have built an action plan.
It is the sequence, the deadlines, a decision tree that routes you to your own entry point in a single question, and comment templates with the openings and closings written and a deliberate hole in the middle where the only paragraph that matters goes. There is a card built specifically to be forwarded to colleagues in the other twelve professions who are paid off the same fee schedule we are, because the most useful thing any of us can do is make sure the next filing is not another dietitian’s.
Every payment mechanism in it is quoted from the statute or the Code of Federal Regulations rather than from anyone’s summary, including my own earlier ones. I found two things I had been describing imprecisely for a year while I was checking.
If you hold a leadership, director or chair role at state or national level, an affiliate board, a licensing board, a committee chair, a program directorship, message me and I will send it. I would rather it be used than admired.
If you are not in one of those roles, you almost certainly know somebody who is. A program director, a board member, someone who chairs a committee, someone who sits on a licensing board. Forward this to them.
That is not a small thing to ask and it is not a consolation prize. Most of what is in this series can only be acted on by people in those seats, and most of those people have no idea any of these deadlines exist. I did not, until this year. One forward from someone who knows them is worth more than my writing another paragraph.
And everything an individual can do will be in the pieces themselves, starting tomorrow.
A note on who pays for this
Nobody does.
There is no institution behind this work, no grant, and no organization underwriting the time, the document fees, or the research. I am a working clinical dietitian, and the pulling of statutes and fee schedules and comment dockets happens around a hospital job.
Everything I publish stays free, and it will. If it is useful to you and you can afford it, a paid subscription is what funds the next one and the advocacy that goes with it. If you cannot, that is genuinely fine, and forwarding this to one person who is in a position to act on it is worth more to me than the subscription is.
Tomorrow
No. 1 runs in the morning. It is about two sentences in a federal rule that sit one page apart and say opposite things, and about a comment period that closes on 14 September.
I am a registered dietitian, and several of the outcomes argued for in this series would improve the economics of my own profession and my own practice. That is a direct interest and it should be weighed against everything I write here.
This article is general nutrition education, not individualized medical or nutrition advice, and it does not create a dietitian–client relationship. Medications and their side effects should be managed with your prescribing clinician. See the full disclaimer.