Members ask their coaches about everything. Whether to skip a dose before a trip. What to eat after a new diagnosis. Whether a supplement's worth the money. And sometimes, at the end of a hard week, something that has nothing to do with habits at all.
How a coach answers in that moment is a scope of practice question, and on most teams it's left to each coach's judgment. Here's where the line sits, where it actually gets enforced, and how to make it a team policy instead of a judgment call.
What a health coach's job actually is
The National Board for Health and Wellness Coaching (NBHWC), which certifies coaches, publishes the profession's scope of practice. It describes the coach as an accountability partner, not a director. Coaches help members set their own goals, draw on their own strengths and build the habits that get them there, in line with whatever treatment plan their clinicians have already set.
Two things widen that lane. Coaches can share evidence-based information from nationally recognized authorities. And when they're working under the license of a physician, psychologist or other qualified professional, they can help a member carry out that professional's treatment plan. That matters for Medicare's proposed coaching codes, which would have a billing practitioner supervising the coach's work.
Where coaching stops
On their own, the NBHWC says, coaches don't do any of the following. We've put its list in plainer terms.
The same list also rules out consulting and advising. In our experience that's the one coaches drift into without noticing: telling a member what to do instead of helping them decide.
Coaches who also hold a license, such as a registered dietitian or nurse, can work within that license too. The NBHWC's condition is that the dual role is discussed with the member and documented from the start.
Nutrition is where the line gets enforced
Of everything on that list, food is where crossing the line can cost you, because state dietetics laws carry penalties.
One case shows how that plays out. Heather Del Castillo was a health coach who ran her business mostly online. According to the federal appeals court that heard her case, she tailored dietary advice to each client and recommended vitamin supplements to some. In 2017 a licensed dietitian complained to Florida's health department, an investigator posed as a client, and she paid:
Florida changed the law in 2020, before her appeal was decided. General nutrition advice no longer needed a license, unless the client was under a doctor's care for a condition that needs nutrition intervention (obesity and weight loss don't count) or the adviser claimed to be a dietitian. Del Castillo kept fighting because she wanted to keep serving clients under a doctor's care, and in 2022 the Eleventh Circuit ruled against her free speech challenge.
Nebraska draws a similar line. Its nutrition law, as the Academy of Nutrition and Dietetics publishes it, specifically exempts health coaching and individualized nutrition guidance that doesn't amount to medical nutrition therapy, as long as the coach isn't claiming to be a licensed dietitian.
For a virtual team, the catch is that every state writes its own version of that line. The Academy recommends that practitioners hold a license in every state where their clients are located. Our read is that coaching teams should plan the same way: the rules that count are the ones in the member's state, not yours. This isn't legal advice, so check your states with counsel. In the meantime, keep nutrition conversations on the member's goals and habits, and send anything that sounds like a diet for a medical condition to a dietitian.
How to set a coach scope of practice policy
Scope shouldn't live in each coach's head. Write it down once, train to it, and check it in reviews. Here's what we'd put in it.
What coaches can say instead
A handoff shouldn't feel like a door closing. The coach still helps, just with the part that's theirs. Here's how we'd coach it.
| Member asks | Coach can say |
|---|---|
| “Should I skip my shot this week? I'm traveling.” | “That's one for your prescriber. Want to jot down what you'd ask them, so the call's quick?” |
| “Can you just tell me what to eat?” | “Meal plans are a dietitian's job, and I can help you find one. What I can do is work with you on the meal that's hardest for you right now.” |
| “I've been really down. What's even the point?” | “Thank you for telling me. Before we talk about anything else, I want to make sure you're OK.” Then the crisis procedure, every time. |
Where the platform fits
A written policy only works if coaches can follow it mid-conversation. Avidon doesn't decide scope for you, but it holds the pieces that make a policy easy to follow. Coaches keep notes, assessments and secure attachments on the member's record, so a referral is documented where the next person will look, and an audit log tracks activity. Members keep the same coach throughout, so the coach who made the referral is the one who follows up. If you're comparing coaching platforms, ask each one where referrals get documented and who can see them.
And when a member wants more on food, sleep or stress than a coach should improvise, there's somewhere to send them. Avidon's 40-plus self-paced courses are written by a team that includes medical doctors, clinical psychologists, registered dietitians and certified health coaches. The coach keeps coaching, and the content doesn't depend on any one coach's background.
