This week’s “Ftag of the Week” on the CMSCG Blog is F809 Frequency of Meals/ Snacks at Bedtime, which is part of the Food and Nutrition Services regulatory group. The basic requirements of this regulation have stayed the same, but emphasis on resident choice has been added.
First, the regulation states that residents must receive, and the facility must provide, at least three meals per day. These meals must be served “at regular times” based on normal mealtimes in the community, or, adding in the person-centered focus, may also be served in accordance with resident needs, preferences, requests and plan of care. The second section of the regulation has remained the same, requiring that no more than 14 hours pass between a “substantial evening meal” and breakfast the next morning, except when a nourishing snack is served at bedtime. If a nourishing snack, which is comprised of an item or items from the basic food groups, is served, then 16 hours may separate the meals so long as a resident group has agreed to this meal plan.
What’s new, however, is the requirement that “suitable, nourishing alternative meals and snacks,” – meals/snacks that are of similar nutritive value as the meal/snack that is offered during normally scheduled meals and consistent with the resident’s plan of care – must be provided to residents who prefer to eat at non-traditional times or outside of scheduled meal times, so long as this is consistent with the care plan. The IG notes that this does not mean nursing facilities have to provide food service 24 hours per day and that it is acceptable to prepare suitable alternatives in advance that can be “appropriately served by appropriately trained facility staff” at non-traditional times. With the strong emphasis in the RoPs on person-centered care and autonomy, you can expect that surveyors will be interviewing residents to ask them if they like their meal schedules and what input they provide regarding their choices to eat at non-traditional times. Let’s remember what also leads to survey concerns being identified on interview related to snacks; residents can be asked if they are offered snacks at bedtime and if a snack is not offered, would they want one. What do you think that answer if most likely to be?