IFEDD Advocacy Initiatives

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The documents below include more detailed information on the issues and our recommendations.

Update on DSM Severity Criteria: Public Comment Period

In response to IFEDD’s proposal submitted in October 2024, The American Psychiatric Association has released a Correction to the Severity Specifiers of Eating Disorders (Anorexia Nervosa, Bulimia Nervosa, and Binge-Eating Disorder). Per APA procedure, the recommended new guidelines are currently available for public comment before going to the APA Assembly and Board of Trustees for a final vote of approval.

We encourage everyone in the eating disorder community, including treatment providers, affected and recovering individuals, family members, caregivers, advocates, and organizations to submit at least one comment in support of the new criteria before the comment period closes on January 8, 2026. Estimated time to complete: 1 minute.

Why does IFEDD support the new criteria?

Although there are still many recognized problems with the DSM eating disorder criteria as a whole, IFEDD supports this particular change. Previous criteria used only one unrelated factor – BMI for anorexia nervosa, number of binge episodes per week for binge eating disorder, or number of binge/purge episodes per week for bulimia nervosa – to determine severity of an affected person’s condition, rather than the wide range of observed and experienced factors that contribute.

The new severity criteria are the same for all three named eating disorders and respect the diagnosing provider’s clinical judgment:

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• Mild: Few, if any, symptoms in excess of those required to make the diagnosis are present and symptoms and illness-related medical complications result in no more than minor impairment in social or occupational functioning.
• Moderate: Symptoms, functional impairment, and illness-related medical complications between “mild” and “severe” are present.
• Severe: Many symptoms in excess of those required to make the diagnosis, or several symptoms that are particularly severe, are present, or the symptoms result in marked impairment in social or occupational functioning or in serious and potentially life-threatening illness-related medical complications.

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If you’re ready to submit your comment, click here: https://tinyurl.com/SeverityCriteriaComment

There is no option to submit your comment anonymously, so if you prefer not to give your name and email address, please send your comment here: info@eddietitians.com and we will submit it anonymously for you.

If you’re unsure what to say, here are some possibilities to choose from. You can also write your own comment and/or share your personal experience.

1. These changes move the field closer to clinical reality. Symptom severity and functional impairment have always been more meaningful than BMI or episode counts when assessing risk.
2. The new criteria using medical complications acknowledge what providers see every day: severity cannot be captured by numbers alone.
3. This update allows clinicians to document the true level of impairment and risk of each patient.
4. The shift away from BMI-based specifiers is long overdue. BMI has always been a poor proxy for illness severity, and this proposal reflects the current evidence base.
5. Emphasizing functional impairment highlights the fallout that eating disorders cause in all areas of life—factors that often determine safety far more than weight or episode count—and providers can still use extremes of BMI or binge/purge frequency in decision-making if they wish.
6. This correction better captures the complexity of eating-disorder presentations and makes space for individualized clinical judgment, a glaring omission from the previous specifiers.
7. The recognition that compensatory-behavior frequency or binge frequency alone cannot fully describe severity represents meaningful progress in diagnosing eating disorders.
8. These revisions strengthen the diagnostic framework and may help reduce misclassification, particularly in individuals whose medical risk is not reflected in current specifier thresholds.
9. A more nuanced severity structure will improve access to care and hopefully patient and family willingness to seek help.
10. The new criteria give clinicians more accurate language to explain to patients and families the severity of their illness.
11. These changes finally recognize that eating-disorder severity is about medical risk and functional impairment—not numbers on a scale or behavior tallies. This is a major step out of the dark ages.
12. The change means diagnostic language will better reflect the true danger of eating disorders.
13. Prioritizing medical complications and functional decline means that doctors may now be better listeners to patients who “don’t look sick.”
14. The old standards were arbitrary and had no basis in evidence-based care. In fact they made the APA seem out of date and passé.
15. Aligning severity with real-world clinical risk makes the DSM more ethical, more patient-centered, and less dependent on outdated assumptions.
16. Recognizing severity through multiple domains will lead to better assessment, earlier diagnosis, and more proactive treatment planning, ideally lowering treatment costs due to earlier intervention, shorter stays, and lower relapse rates.
17. Parents of medically vulnerable children who didn’t meet the previous numeric criteria are breathing a sigh of relief that their child’s suffering will no longer be ignored.
18. This shift toward multidimensional severity specifiers is a win for the recognition that eating disorders are complex and need treaters with expertise.
19. These improved severity specifiers reflect what we see in practice—risk is multifactorial, and BMI or behavior frequency alone has never captured the full clinical picture.
20. I appreciate that the revision allows for increased severity based on medical instability. This better aligns diagnostic coding with treatment needs.

For more information on the background that prompted this correction, see “Proposal to the American Psychiatric Association: Revert Diagnosis “Severity” Specifiers Back to Discretionary Status by the Provider” lower down on this page.

Please share this information with your colleagues and other members of your family and organizations, on social media and in any online groups, and encourage them to submit a comment. The direct link to this page is https://ifedd.org/advocacy and you can screenshot this graphic to post along with the link.

To read the APA announcement, click here: https://www.psychiatry.org/psychiatrists/practice/dsm/proposed-changes

IFEDD’s Press Release about the announcement is below.

Please share widely and direct any questions to info@eddietitians.com.

Request to the Secretary of Veteran’s Affairs: Allow Dietitians to Continue Remote Work if Needed to Assure Patient Safety and Confidentiality

Proposal to the American Psychiatric Association: Revert Diagnosis “Severity” Specifiers Back to Discretionary Status by the Provider

Documentation of Concerns Regarding Eating Disorder MNT Claims Presented to Federal Regulators of the Mental Health Parity and Addiction Equity (MHPAEA) Proposed Rule Clarification July 2024

IFEDD’s Comment on the Mental Health Parity and Addiction Equity (MHPAEA) Proposed Rule Clarification Submitted October 2023

The text of the MHPAEA Clarification Rule, i.e. the full proposal of revised regulations, can be accessed here: https://www.federalregister.gov/documents/2023/08/03/2023-15945/requirements-related-to-the-mental-health-parity-and-addiction-equity-act .

The Nutrition CARE Act

Nutrition Counseling Aiding Recovery for Eating Disorders Act of 2023, also known as The Nutrition CARE Act, would fix a gap in Medicare Part B coverage, which excludes individuals with eating disorders from receiving Medical Nutrition Therapy. Currently, Medicare doesn’t cover members for meetings with their dietitian. This also applies to individuals with Social Security Disability.

To learn more, view the Eating Disorder Coalition’s Nutrition CARE Act infographic.

The full text of The Nutrition CARE Act can be accessed here: https://www.congress.gov/bill/118th-congress/senate-bill/3010/text.

To be aware of action alerts related to The Nutrition CARE Act, join our mailing list.

The Eating Disorder Coalition’s Advocacy Day on Capitol Hill

Every year, IFEDD sends member delegates to The Eating Disorder Coalition’s Advocacy Day. Delegates meet with US Congressional staffers who directly influence legislation. In 2024, Advocacy Day once again returned to in-person meetings, and 11 IFEDD members from as far away as California and Alaska gathered in Washington, DC, to participate.

Our Mission: Stop Insurance Discrimination Against Individuals Living with Eating Disorders

IFEDD was founded with the specific goal of improving access to nutrition services for individuals with eating disorders. By gathering eating disorder dietitians in a way that had never been done before, IFEDD has been able to demonstrate that illegal insurance discrimination against individuals with eating disorders is rampant throughout the US and not limited to any one company, location, provider or patient.

There seems to be no incentive for insurers to follow the law because there is no enforcement. We continue to work through multiple channels to help individuals get coverage and to encourage insurers to solve the problems internally before regulators and legislators get involved.

If you lead an insurance company and would like to know if you are part of the problem, please contact CARE@IFEDD.org.

If you are personally experiencing insurance discrimination and would like help, please see our Help with Insurance Denials page or email CARE@IFEDD.org.