2017 CMS LTC Requirement Phase II: Expectations & Compliance
§483.60 Food and Nutrition Services - CDM, CFPP Credential Timeline:
- The Certified Dietary Manager, Certified Food Protection Professional (CDM, CFPP) credential as of November 28, 2017 is being enforced as a qualifier to be the Director of Food and Nutrition Services in the absence of a full-time dietitian.
Food Service Directors hired after November 28, 2016 MUST NOW MEET staffing requirements. CDM, CFPPs are listed as the primary qualification in the CMS regulations.
November 28, 2017 | Phase II
Food Service Directors employed in a facility prior to November 28, 2016 and are not certified or do not meet other qualifications to be the Director of Food and Nutrition Services, have five years to obtain certification.
What if the facility FSD is taking the course and does not have their certification by November 28, 2017?
Facilities would be considered out of compliance for the regulation after November 28, 2017 if the person did not meet any of the criteria outlined. As with any potential regulatory non-compliance, a facility would have the opportunity to present the plan in place to bring themselves into compliance and the state survey department would then decide if the facility would receive a deficiency or not.
What documents should a FSD have to prove compliance?
Regulations Intent: §483.60(a) Stafﬁng - The facility must employ sufficient staff with the appropriate competencies and skills sets to carry out the functions of the food and nutrition service
CDM, CFPP certificate and recent renewal documentation should be on file with your facility’s human resources department. Current certification status can be verified online HERE. Students actively seeking certification should have their educational institutions acceptance letters/proof of course enrollment in their human resources file.
Does your facility have written competencies for all your food and nutrition services staff and should they be signed?
Regulations Intent: §483.60(c) Menus and Nutritional Accuracy
As a CDM, CFPP, the Scope of Practice provided by ANFP is your competency checklist! Food and nutrition services staff should have facility specific competencies that are completed. For example, upon hire, during performance evaluations, and when you have a new procedure or piece of equipment that needs in-service prior to use. These competencies should be dated and signed with both the trainee and trainer’s signatures providing proof to ensure the skillsets of your food and nutrition services personnel. Use the 2017 New Survey Pathways for Dining and Kitchen as a template to create your facility’s competency checklist!
(4) Reflect the religious, cultural, and ethnic needs of the resident...
Do all my menu items have to be Halal for just one resident requesting it?
The facility must make "reasonable" efforts to provide food that is appetizing and culturally appropriate for residents. Alternatives should be available to accommodate these individual needs. The facility should care plan cultural preferences and the accommodations made to meet the resident’s preferences.
(6) Be reviewed by the facility's dietitian…for nutritional adequacy
My facility spreadsheets are written/approved by our food suppliers corporate dietitian. Does that qualify as the dietitian review?
The facility-purchased menu systems needs to be reviewed, signed, and dated by your in-house consultant/dietitian and you, as the CDM, CFPP, for each week and every cycle i.e. Fall/Winter/Spring/Summer to be sure they meet the needs of your residents. Any changes made, once signed off by the Registered Dietitian and CDM, CFPP, need to be approved as well.
Regulations Intent: §483.60 (f) Frequency of meals & §483.60 (g) Assistive devices
(2) Suitable, nourishing alternative meals and snacks must be available for residents who want to eat at non-traditional times or outside of scheduled meal service times and in accordance with the plan of care
The facility must provide special eating equipment and utensils...resident can use the assistive devices when consuming meals and snacks
Do I need to have a person deliver snacks every evening, every night of the week?
Regulations Intent: §483.60 (i) Food safety requirements
"Snacks must be available," so you and your leaders need to create a policy. For example, snack cupboard, snack basket, and snack refrigerator are good options. Food and nutrition services finds appropriate offerings, keeping in mind any consistency issues. Puddings, flavored applesauce, and yogurt in a tube are good for purées, however watch for items with nuts and gluten. Stock a good variety, educate nursing staff regarding the choices, making them available 24/7 so if a resident wants a midnight snack, one is available. BE SURE to have any adaptive equipment available for use, such as a spouted cup or a built up spoon.
(ii) This provision does not prohibit or prevent facilities from using produce grown in facility gardens, subject to compliance with applicable safe growing and food-handling practices.
(3) Have a policy regarding use and storage of foods brought to residents by family and other visitors to ensure safe and sanitary storage, handling, and consumption
Safe food handling Policies need to be written to be facility specific to address food grown on site and food brought in. Be sure and share in your facility newsletters and family meetings and consider posting the policy in a public area for visitors to review.
§483.21 Comprehensive person-centered care planning (a) Baseline care plan
Who does this for Food and Nutrition Services: CDM, CFPP or the Consultant RDN?
Since this is required upon admission and timeliness is a concern, it would be best to have the CDM, CFPP responsible for the initial baseline documentation/care plan. Then, the RDN can provide supporting documentation when he or she available to complete an initial assessment.