Up next on the CMSCG Blog “Ftag of the Week” series is the third most frequently cited deficiency on survey in the United States, F812, Food Procurement, Store/Prepare/Serve – Sanitary. This regulation is part of the Food and Nutrition Services regulatory group and is routinely one of the most frequently cited regulations, so most facilities can benefit from a review of their systems for this area. Since F812 covers a significant amount of information, we will be covering this Ftag over the next several posts.
Procurement
The regulation at F812 requires that nursing facilities procure food from approved sources or sources that are considered satisfactory by federal/state/local authorities. This includes local producers if this is permissible under state/local law. It also allows facilities to use produce that has been grown in facility gardens under two conditions. First, to use the produce from the facility gardens, there must be policies and procedures in place that are being followed for maintaining and harvesting their gardens. These P&Ps should ensure that manufacturer’s instructions are followed if any treatments (i.e. pesticides or fertilizers) will be used. Facilities must also be compliant with any state/local requirements governing food grown on facility grounds that will be used for resident consumption, so it is important to be aware of these requirements as well.
Storage
F812 requires that facilities follow professional standards for food service safety with regard to storage, preparation, distribution and serving of food. The regulation states that CMS recognizes the US FDA Food Code and the CDC’s food safety guidance as the national standards for these topics in long-term care facilities. The regulatory requirements for this area are quite lengthy and very specific as to expectations, so we will delve into these in more detail in the next few posts.
The definition of storage as it relates to F812 includes the retention of food before preparation and after preparation, as well as the associated dry goods. The regulation requires that when food/beverage products are delivered to the facility, that staff inspect them for safe transport and acceptable quality. Staff must then ensure that these items are properly stored, track when perishable foods need to be discarded and covered, and ensure that all Potentially Hazardous Foods (PHF) and/or Time/Temperature Control for Safety (TCS) Foods stored in the refrigerator or freezer are labeled and dated as required.
Dry Food Storage
Food items that are not PHF/TCS foods that are kept in dry storage should be kept in contaminant-free containers.
- Dry food and goods are expected to be handled in a manner that maintains the integrity of the packaging until it is time to be used. Foods that will be stored in bins should be removed from this packaging.
- Food and food products should not be stored on the floor or near ceiling sprinklers, sewage/waste disposal pipes or vents.
The regulation notes that good practices for managing storage include knowing how to receive and store these items properly, removing items that are not safe for consumption, keeping dry food products in closed containers and rotating inventory.
Refrigerated Storage
Foods that are considered PHF/TCS foods must be stored with several requirements in mind. These include ensuring that:
- Any foods stored in walk-in units are not stored on the floor
- PHF/TCS foods are maintained at 41 degrees F or lower (unless otherwise specified by law)
- Frozen foods are maintained at a temperature that keeps them frozen solid
- There is adequate air circulation around refrigerated products to keep them at appropriate temperatures
The regulation provides a detailed list for maintaining safe refrigeration storage temperatures that should be part of the facility’s monitoring systems and routinely audited. These include:
- Monitoring food temperatures (daily/routinely)
- Labeling, dating and monitoring refrigerated food items to ensure items are used, discarded or frozen (if applicable) by their use-by dates
- Keeping raw foods separated from each other, and storing raw meats on shelves below ready-to-eat foods to prevent contamination
- Utilizing containers that allow food to cool rapidly
- Ensuring refrigeration equipment is functioning appropriately (daily/routinely)
Regarding the last bullet point about refrigerator and freezer functioning, CMS has included guidance for surveyors that facilities can use to ensure these units are operating properly. These checks include:
- Routinely documenting the temperatures on both internal and external gauges and the internal refrigerator temperature. When doing this documentation, also measuring the temperature of a PHF/TCS food to ensure it is at 41 degrees or lower.
- Checking frozen foods to ensure they are frozen solid and inspecting the frozen food items’ wrappers to ensure they are able to adequately protect these items
- Looking inside the units for potential cross-contamination situations, such as where raw meat is being stored above other items
- Checking to see if a food item with a prolonged cooling time is in the danger zone by taking its temperature to ensure the cooling process is effective for that PHF/TCS food item.
During survey, surveyors will check for food storage practices that could create contamination issues, such as ice buildup, evidence of pests, dry goods with compromised seals, temperatures of facility refrigerators, including unit refrigerators. It is important to ensure staff are appropriately monitoring and documenting temperatures where necessary, and if issues arise, that Maintenance is apprised so the units can be serviced.
Stay tuned for more information on F812 in next week’s Ftag of the Week.