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Mike: Welcome back, everyone, to another exciting episode of Cosmic Soup. I am freakin’ excited to be here. You know why? That’s right. It’s F-Tag Friday, and we’re making good on our promise to decode and demystify these troublesome tags so that you can stay out of hot water and keep The Man off your back.

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Mike: With me, of course, is the legendary Randi Saeter and her magical super-secret decoder ring. Hey, Randi. Welcome to episode 2 of F-Tag Friday. What do you got for us today?

Randi: Well, today we’re going to talk about again the food and nutrition services F-Tags: F801 and F802. It refers to communities having qualified dietary staff and sufficient staff as well (in their departments).

Mike: Ooh, so we’re talking about two drastically important things that are also facing major challenges, number one in terms of overall staff (especially during COVID), and then the probably highly controversial “qualified” staff. Tell us more about this then. What’s going on with this F-Tag.

Randi: Yeah. You know it’s interesting. Even though we have the pandemic going on, the requirements remain the same. We understand communities struggle so much with finding enough staff. But yet again, we have to have qualified staff in place because we still have to make sure that our residents are fed and that they’re well taken care of.

F801: Qualified Dietary Staff, this refers to the regulation that actually was recently changed with some education requirements for the people that are in charge of the dining services department, so the bosses.

Mike: Oh…

Randi: [Laughter] And we want to make sure we have qualified bosses around. Basically, what it states is that you have to have a registered dietitian on staff either full or part-time or as a consultant. This registered dietitian has to be licensed in the state that they’re working in as well as being registered by the Commission of Dietetic Registration, which is a national commission.

Now, if you don’t have a dietitian on staff full time, then you also have to have a person. You need to designate a person who will serve as the director of food and nutrition in your community. There’s a long list of requirements that they have to meet in order to be qualified for this position.

Mike: Yeah, so when we’re talking about qualifications, it’s not just a matter of somebody saying, “Oh, I think you’ve got good experience and you’re good enough.” You have to literally have the certifications and the accreditations behind you to be able to even have these jobs. Correct?

Randi: That is very, very correct because registered dietitians come in and they evaluate or assess the residents. Yes, you need to know what you’re doing in terms of clinical assessments and making recommendations to doctors in terms of their care plan.

For a dietitian, we are obligated to have a bachelor’s degree from an accredited college or university within the United States. We also have to have a minimum of 900 hours of supervised practice under the supervision of a registered dietitian or a professional.

That’s what I went through in my college years, which felt like a lengthy road during the time.

[Laughter]

Randi: But you have to have that in order to be able to then evaluate these very vulnerable elderly seniors in our communities.

Mike: Yeah, well, that makes sense. If I was going to go into a skilled nursing program, or if one of my relatives was going to go into one, I would want to feel like there are the right people in place to ensure their safety and wellbeing.

Randi: Exactly. Yes, so when you have a dietitian who is only part-time and they come in and do the clinical side of things in terms of the resident care, then you have to have someone (again, the director of food and nutrition) and they need to be either a certified dietary manager or something similar to that with an associates degree. Also, they need to meet state requirements for those types of positions as well. Again, like you said, you can’t just come in and say, “Oh, I think I want to do this job.” There needs to be some educational background with it.

Mike: Yeah. A little different in the case, for instance, in the regular culinary field, you can have a lot of chefs who are fantastic chefs who may or may not have been through culinary school, who may or may not have decades of experience behind them but are able to go into a place and just make super awesome food that rules. Everybody is like, “Wow! This is the best food I’ve ever had.” You can’t do that in the skilled nursing environment. You have to have those credentials behind you besides just having a skillset to practice your profession.

Randi: Exactly, yeah, so a chef could come in. I would love to have more chefs in these types of communities because I think they bring so much to the table. They can go in. Based on their experience, they can go in then and take a quick course to become a certified dietary manager and take a test, so they would be qualified then. That’s what I would love to see more of, actually, in these communities because, again, I think that they can make so many great changes for our residents.

Mike: I’m glad you brought that up. I think that’s awesome. For a chef to become a CDM is not really that big of an obstacle.

Randi: No, it shouldn’t be because they have to take some classes on infection control, on just the different types of sanitation classes, and areas like that. I think that in their training, if they’re a chef already, they probably had that in school, so it just would be a matter of studying back up again and then taking that test.

Mike: Yeah, and a lot of that stuff is also commonplace in things like Serve Safe Certifications.

Randi: Mm-hmm.

Mike: Or any other number of courses out there that will actually give you credits for taking those.

Randi: Absolutely.

Mike: What other positions might be required to meet this particular F-Tag requirement, or is it just those two?

Randi: Well, we also need to have sufficient dietary support personnel, and that falls under that F802. That just means that your line staff, while you have to get them educated and trained, you have to make sure that all positions are filled so that they’re putting out food that is great for our residents and that they know what they’re doing.

If they don’t get enough training and you don’t check that they know what they’re doing, there could be some violations. There could be some hazards involved with that.

If you don’t know how to properly wash your hands or properly prepare some food, we know that that could cause various issues such as even foodborne illness and cross-contamination. You have to make sure not only that you hire good people, that you train them, and then you do competency checks on them, too, on a pretty frequent basis to make sure that they’re okay within their job duties.

Mike: You know what blows my mind, Randi?

[Laughter]

Mike: There’s a lot of stuff that blows my mind, but since you mention that, you know, following up and checking up, back in the day there used to be this thing called a performance evaluation or a review.

Randi: Uh-huh.

Mike: It just doesn’t seem to happen anymore. Is this the same in, say skilled nursing arenas that people aren’t getting followed up on?

Randi: I think that’s very, very common, and I think that’s why, too, the government has put a bigger emphasis on making sure that communities adhere to this guidance and that they’re actually doing it because now the surveyors come in and ask for a copy of those performance evaluations. It’s not just a review, but it contains action items that you have to follow up on, so competency. That is pretty new within the last few years that you have to make sure that they have the skills and abilities to do the job properly.

It makes sense. It seems like, “Oh, my gosh. Now I have to do so much more for my work here,” but it makes sense because you want to make sure that they’re doing things right. Ultimately, we’re serving the residents, and they have to be safe (at the end of the day). That’s why the government is putting this extra effort and focus on these areas.

Mike: Can a community be cited if they don’t have enough employees in these areas?

Randi: Yeah, they can be. Absolutely. In these areas, what it ties back to is if you’re not serving meals on time, you’re serving subpar quality food, they’re going to really put a hyper-focus on these areas and check to see, “Okay, let me look at your staffing grid. How many people did you have on staff yesterday? Let’s go back two weeks, and let’s look at that and investigate as to why you’re having these issues.”

If you’re not having enough staff, that’s just a given that you’re not going to be able to produce great food. Yeah, they look at that, absolutely.

Mike: As we talked about earlier, it’s a very challenging time right now. I think that the mentality that a lot of administrators and a lot of management staff have is, “Well, I’m understaffed, so I’ll just work extra hours or I’ll ask my employees to work extra hours.” Then sometimes, as a result of that, employees just say, “I’ve had enough,” and then they go. Now you’re twice as short, right?

Randi: Mm-hmm.

Mike: I think there is a challenge in maintaining those staff levels and, of course, maintaining the quality and the controls behind that. Do you have any recommendations? I know that this is just asking for you on a personal insight level, but what are some ideas to maybe help make sure places stay staffed? What can the administrators do to make sure that they’re not going to get cited for these violations?

Randi: Well, I think that first of all, you have to have a great work environment with a supportive boss, the dining supervisor. Again, in terms of support, administration and, of course, money plays a big role, too, because people are not going to work extra-extra hard for little money. They want to be paid competitively, and I think that all CEOs and administrators always need to do salary surveys to make sure that the dining staff land where they’re supposed to because otherwise, they’re just going to go elsewhere. They’re going to go to the neighboring community and get paid more.

They need to focus on that. In addition, they need to make sure, yes, that they are receiving the proper training, that they’re not overworked. If the dining supervisor needs to step in here and there, I think that just sets a great example for showing support and showing that they’re not too good to step in and work on the line if needed. That way you can build more of a cohesive team.

I know right now it’s very challenging out there because of the pandemic. People are not wanting to work in these communities because of the risk of getting sick and whatnot, too. But if you just focus on the individuals, you check in with them, and you show them that you care, I think that goes a long way, too.

Mike: What else do we need to know about 801 and 802?

Randi: It’s just that all of these things, they actually go back to something that we call the facility assessment. This is also a regulation. Everything gets tied in with that, so the number of staff you have in the department has to be documented, and that’s something that the surveyors will pull on day one upon annual inspection. So, I would just suggest that you document this now.

Make sure you know what you have within your department now so you don’t have to scramble when they come in. Make sure that these staffing levels are sufficient to meet the needs of all the residents in terms of dining and that it’s accurate. Again, you don’t want to have to go and look like a question mark when the surveyors come in.

You want to make sure you have that document, and that’s something you would do with your administrator. If you don’t have that as a dining services director, then touch base with your administrator and make sure that gets documented.

Mike: Absolutely. If I may throw one quick blurb in here, a good, I guess, best practice that is common not only in the restaurant business but in retail land and any other professional environment is (as a manager, as an administrator, or as somebody in the leadership role) always be interviewing even if you think you don’t need bodies because—trust me—at some point you’ll need the bodies, and you always want to have what we call “bench.”

Randi: Mm-hmm.

Mike: Which is just a list of people that you can go to when that time happens. Sure, you might interview people and not have a spot for them, or you might find somebody you like so much you make a spot for them.

Randi: Yes.

Mike: Those that choose to only interview after people leave, you’re setting yourself up for failure and you’re just making your life that much harder. Do weekly interviews, biweekly interviews, monthly interviews, or just put some kind of a system in place where you’re always talking to talent, trying to retain talent, partner with your HR directors, or whatever you have to do to make that happen.

Staying ahead of the game in terms of possible employees and team members really makes your life that much easier.

Randi: Totally agree and well said.

Mike: Well, thanks, Randi. I appreciate the conversation about these two F-Tags. We’ll do this again real soon.

Randi: Okay. Thank you so much.

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Mike: Well, there you have it. Moral of the story: Keeping your community staffed with appropriately qualified team members isn’t just a suggestion for convenience and sanity. It’s actually a federal requirement.

We know it’s tough out there right now, especially with the pandemic. So, if you’re really struggling, feel free to send an email to cosmicsoup@3rd3rd.com, and we’ll put you in touch with one of our community or culinary coaches.

Well, that’s it for this F-Tag Friday, but there’s more on the way, so stay tuned and we’ll see you soon on Cosmic Soup.

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