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Nutrition Services to Face Increased Regulatory Challenges

Person-centered dining is now a required facility initiative.  With increased attention on resident preferences and satisfaction, regulatory agencies needed to keep up.  This along with the dining enhancement trends in long-term care brings Food and Nutrition Service departments from the back of the house to center stage of any facility focused agenda for 2017.   The Centers for Medicare & Medicaid Services (CMS) published the final Requirements of Participation in October 2016 which contains new requirements surrounding nutrition specifically the dietary department.  The effective date for these new regulations was Nov. 28, 2016, with three phases and time frames for implementation.  This useful checklist can assist you in meeting compliance and possibly build your QAPI plan for 2017 as it relates to Nutrition Services.

If you answer NO to any of the below or if you feel this is an area of weakness you may consider adding this to your 2017 QAPI plan.

Does your facility support “person-centered” care through dining and nutrition services by:

  • Taking resident preferences into consideration-
    • Q: Does your facility do a food intake/preference tool to capture this data timely upon admission specifically on food likes/dislikes/allergies and cultural preferences?
    • Note: I recommend a copy of this record in both the EMR and dietary system if they are not interfaced.  This should include desired meal times and locations.
  • Hire/train sufficient staff to carry out the functions of the department-
    • Q: Do you have a department specific education module focused on job tasks, competencies and food service safety.
    • Note: I recommend maintaining a calendar for the year of monthly departmental educational sessions.
  • Employ a qualified dietitian on FT, PT or Consultant-basis.-
    • Note: Nothing new except you may need to confirm that the dietitian in your facility is one who is either registered by the Commission on Dietetic Registration of the American Dietetic Association or as permitted by state law, on the basis of education, training, or experience in identification of dietary needs, planning, and implementation of dietary programs.
  • Employ a director of food and nutrition if not a qualified dietitian FT, meet one of the following:
    • Note: Be a Certified Dietary Manager or Certified Food Service Manager as evidenced by meeting national certification standards for a certified dietary manager such as those by the Association of Nutrition and Foodservice Professionals (ANFP), or for a certified food manager such as those by the International Food Service Executives Association of the Food Management Professional certification through the National Restaurant Association.
    • Note: This may be a challenge however facilities are given some time to get this accomplished.  This individual must meet the specified criteria no later than five years after Nov. 28, 2016, if they were already serving in that position, or no later than one year after Nov. 28, 2016, if designated after Nov. 28, 2016.
  • Include a member of the food and nutrition services participate in the IDT team.
    • Q: Do you have a voice for this department in attendance?
    • Q: Is the information collected during these IDT meetings reflected of the food/nutrition services provided in the residents’ plan of care?
  • Menus meet established national guidelines or industry standards.
    • Note: Incorporate 2015-2020 Dietary Guidelines or MyPlate for Older Adults in your menu preparations.
  • Menus meet religious, cultural and ethnic needs of the residents as well as input from resident groups.
    • Q: Does your community have a process for meeting this requirement?
    • Note: A formalized Food Committee made up of residents, involved family members, and key staff should be considered.
    • Note: This is also a key question that should be reviewed occasionally with each resident on a Food Preference Tool.
  • Diet orders prescribed by a physician or if delegated by a physician, to a qualified dietitian or another clinically qualified nutrition professional, to the extent allowed by state law.
    • Note: The Academy of Nutrition and Dietetics has a great tool to confirm your states approval for order writing privileges outside of MD.
  • Meal times that meet in accordance with resident needs, preferences, requests and the plan of care-
    • Q: Did you confirm what time the resident likes to eat each meal?
    • Note: This now includes the liberalization of that ever challenging 14- hour rule between a substantial evening meal and breakfast the following day.  Document the desired meal time on your FPT.
  • Provide suitable nourishing alternative meals or snack if the resident missed a meal or wanted at non-traditional or scheduled times.-
    • Q: Do you have pre-planned alternative meal options for your community?
    • Note: Work with your food manager, food committee members, and menu development program to create your ideal solution.
  • Provide adaptive eating/drinking devices with assistance for use as needed-
    • Q: Is this clarified in their care plan, are staff trained in using such devices properly?
    • Q: Do you offer adaptive devices as needed with snacks?
    • Note: A monthly review of residents utilizing adaptive devices is recommended for continued support of independence at meal and snack time.
    • Note: Staff education on proper use of adaptive devices should be ongoing.
  • Use food from your facility garden, if so is there a policy being followed for safe growing and handling practices to include the use of pesticides in accordance with manufacturers’ instructions.
    • Note: Incorporate a facility garden policy meeting the standards and have it reviewed by Risk Management, Facilities Management for any suggestive items to be included.
  • A policy to store and use foods brought to residents by visitors to ensure safe and sanitary handling
    • Note: Policy development and approval process and education to all facility staff.

Matrixcare’s own MealTracker helps communities meet these challenges daily with elite software created around resident specific food preferences.  Promoting self-determination of menu choices, meal times, adaptive device identification, and dining location while providing specific nutritional menu evaluation, alternative menu options and over 3500 standardized HACCP recipes suited for ideal food safety needs of your community.



The Academy of Nutrition and Dietetics governs the standards of practice for dietetics in long term care and in November 2016 they had released a reference tool for RDN and NDTRs in practice settings to implement the revision of regulations.  http://www.eatrightpro.org/~/media/eatrightpro%20files/practice/quality%20management/quality%20care%20basics/practicetips-reformrequirements-in-ltcfacilities.ashx

Amy Wootton
Amy Wootton

Amy Wootton, RDN, is a registered dietitian licensed in the state of Florida with over 18 years of experience in clinical nutrition leadership for senior communities as well as acute care, food service management, nutrition informatics, and wellness education. Amy is an active member of the Academy of Nutrition and Dietetics, was appointed Vice Chair on the Interoperability and Standards Committee, and is the leader of the Academy’s Nutition Care Process Workgroup. Amy most recently accepted a Leadership Award from the Florida Academy of Dietetics. She has achieved years of diversified experience in all spectrums and disease improvement and prevention throughout each lifespan. Amy is a dedicated leader and is passionate about the success of nutrition interventions as an electronic solution to healthcare crises’.

Nutrition Management Regulations

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