Our next “Ftag of the Week, written by CMSCG Dietary Consultant Danielle Nichtern, MA, RD, CDN, is F802 Sufficient Dietary Support Personnel, which is part of the Food and Nutrition Services regulatory group. Similar to F801, this regulation focuses on staffing requirements. F802 focuses specifically on having sufficient support personnel to “safely carry out the functions of the food and nutrition services.” Additionally, the Centers for Medicare & Medicaid Services (CMS) highlights the need for sufficient staff with appropriate training and competencies. Since “food and nutrition services” broadly refers to all clinical nutrition and food service duties, sufficient personnel will vary by facility.
Aspects to consider include:
- resident population
- size of facility
- acuity of residents and diverse needs
- difference in food production, storage, and distribution methods
For example, think about a centralized dining system vs. decentralized system. The main attraction to decentralized dining is that residents often receive efficient and hot meals with greater flexibility for preferences as meals are served in small unit dining areas. However, decentralized dining may require additional staffing for all unit dining areas compared to a centralized kitchen serving on one tray line and transporting in carts.
CMS guidelines from Appendix PP of the State Operations Manual also state that “a member of the Food and Nutrition Services staff must participate on the interdisciplinary team.” This part of the regulation stresses the importance of attendance and collaboration from the nutritional department in meetings such as care plans, Food Committee, QAPI, etc.
A common complaint regarding meal service is residents’ dissatisfaction with late delivery and meals at an unpleasing temperature. Despite this being a barrier for the Nutrition department to address, it is more often related to a shortage of staff to pass trays and provide feeding assistance, which would not warrant an F802 citation. Compliance with the requirements for F802 is addressed in the Dining Observation Critical Element Pathway and the Kitchen/ Food Service Observation Critical Element Pathway.
Surveyors are guided to determine issues at F802 related to if there are sufficient dietary support staff to carry out meal prep and other services, including preparing and serving meals in a timely manner at appropriate temperatures. If issues are identified, the surveyor may then review the Facility Assessment to determine if staffing levels observed meet those which have been determined as part of that assessment. Have you addressed these staffing needs in your Facility Assessment? It may be worth a review.
