Food and Nutrition Services

• F-801: Qualified Dietary Staff
• F-802: Sufficient Dietary Support Personnel

In any community, it is important to have the right number of staff, but you also want dining staff, chefs and servers who are passionate about what they do. Residents enjoy conversation with employees around meals, and this may be the highlight of their day!

Let’s talk about what the requirements are:

F801 Qualified Dietary Staff, which is part of the Food and Nutrition Services Regulatory Group. This regulation has been in effect since Phase 1 (November 28, 2016) with some of the education requirements waived until 5 years from that date. The Requirements of Participation (RoPs) state that a skilled nursing facility (SNF) needs to employ sufficient staff with the appropriate competencies and skill sets to carry out food and nutrition services functions. The care and services provided need to take into account resident assessments and individual plans of care as well as the SNF’s population based on the Facility Assessment. The regulation at F801 specifically states the requirement for having a qualified dietitian (or other clinically qualified nutrition professional) on staff on a full or part-time basis or as a consultant. The regulation further states that if this qualified staff member is not employed full-time, the SNF must designate a person who will serve as the Director of Food and Nutrition.

Qualified Dietitian/Clinically Qualified Nutritional Professional

The requirements for qualification include:

• Bachelor’s degree or higher from an accredited US college/university with completion of the academic requirements for a program in nutrition or dietetics
• Completion of a minimum of 900 hours of supervised dietetics practice under the supervision of a registered dietitian or nutrition professional
• Licensed or certified as a dietitian or nutrition professional in the State where services are being performed.
• Dietitians hired or contracted with prior to November 28, 2016 have 5 years from that date to meet these requirements or as required by State law.

If the qualified person listed above is not a full-time staff member (35+ hours/week), the facility must designate someone to serve as the Director of Food and Nutrition Services. To be qualified for this role, the individual must:

• Meet the requirements mentioned above within 5 years after November 28, 2016 or no later than 1 year after November 28, 2016 for staff members designated after November 28, 2016.
• Be a certified dietary manager, certified food service manager or have a similar national certification from a national certifying body for food service management and safety
• Have an associate’s degree or higher in food service management or in hospitality if the course study from an accredited institution includes food service or restaurant management
• Meet State requirements for food service managers or dietary managers in States that have such established requirements
• Receive “frequently scheduled consultations” from a qualified dietitian/ nutritional professional

On survey, F801 can be cited because surveyors identify concerns with the qualifications of the facility’s dietitian, clinical nutrition personnel or the food services director, including carrying out the food and nutrition services functions appropriately. This includes nutritional assessments of residents, developing and evaluating regular and therapeutic diets, participating in the QAPI (Quality Assurance Process Improvement) Committee related to food and nutrition services, ensuring all staff receive person-centered food and nutrition services education and overseeing budgeting and procurement. Unfortunately, SNFs have been cited multiple times across the country related to staff not being properly designated for the role and/or not having the appropriate education and credentials.

The dietitian and the Dining Services Director both play an important role in this area. The key is to work together and communicate what is needed in terms of training and education, and take the initiative to establish scheduled, mandatory sessions for all staff that “touch” the residents. Collaboration with other departments is required as nursing staff also will need education and training in the area of food and nutrition services.

If you have not already conducted an assessment of your Dietary Staff against the requirements of F801, the sooner you take a hard look the better as this is an “avoidable” deficiency. Also keep in mind that a compliance investigation related to this F-tag can lead to an investigation of compliance with other regulations such as F686 Pressure Injury, F692 Nutrition/Hydration Status or F693 Tube Feeding Management.

F802 Sufficient Dietary Support Personnel is also part of the Food and Nutrition Services Regulatory Group. It requires that the SNF must employ sufficient staff with the appropriate competencies and skill sets to carry out the out the functions of the food and nutrition service, taking into consideration resident assessments, individual plans of care and the number, acuity and diagnoses of the SNF’s resident population in accordance with the Facility Assessment.

The SNF must provide sufficient support personnel to safely and effectively carry out the functions of the food and nutrition service. A member of the Food and Nutrition Services staff must participate on the interdisciplinary team. Please note that this staff does not include licensed nurses, nursing assistants or “paid feeding assistants” involved in assisting the residents with eating.

When surveyors are at your community and any concerns are identified, they will do the following:

• Through observations and interviews determine if there are sufficient support personnel to safely and effectively carry out the meal preparation and other food and nutrition services as defined by facility management.
• Observe and interview residents to determine if their needs and preferences are met, if the food is palatable, attractive, served at the proper temperatures and at appropriate times. If concerns are identified, determine if they may be related to insufficient or inadequately trained personnel.
• Do observations and/or interviews indicate there are sufficient staff to prepare and serve meals in a timely manner and to maintain food safety and temperature?
• Determine who represents food and nutrition services at interdisciplinary team meetings.

When evaluating timeliness, factors that should be considered include but may not be limited to:

• Meals or nutritional supplements are provided in accordance with a resident’s medication requirements.
• Meals intended to be “hot” are served as such and are maintained at the desired temperature when provided to the resident.
• Meals or nutritional supplements are provided to residents within 45 minutes of either a resident’s request or less depending on the facility’s scheduled time for meals.

Both areas tie back to the Facility Assessment. The Administrator, with input from the Dining Services Director and Registered Dietitian, need to periodically review staffing levels and update the Facility Assessment accordingly as surveyors will refer to this document when making their observations.

For more information on F-Tags and how you can make sure your community in operating in compliance with federal regulations, contact VP of Health Services Randi Saeter at Randi@3rdPlus.com.