Dietary Services Changes to RoPs

As noted in the FY 2023 SNF PPS Final Rule, CMS is proposing changes to F801, however, this was not included in the advanced copy of Appendix PP. The revisions to dietary services were contained in F812 – Food Safety Requirements.

There were revisions to the definition of food distribution to include delivering meals to residents’ rooms or dining areas. In the food distribution definition, CMS also stated that this includes when meals are assembled in the kitchen and then delivered to residents’ rooms or dining areas to be distributed, covering foods is appropriate, either individually or in a mobile food cart. 

The definition of food service was added, which states “the processes involved in actively serving food to the resident. When actively serving residents in a dining room or outside a resident’s room where trained staff are serving food/beverage choices directly from a mobile food cart or steam table, there is no need for food to be covered. However, food should be covered when traveling a distance (such as down a hallway, to a different unit or floor).

Under the interpretative guidance, CMS added information on unsafe food handling be a potential source of pathogen exposure for residents and sanitary conditions must be present in health care food service settings to promote safe food handling. CMS refers to the U.S. FDA Food Code and CDC’s food safety guidance as national standards to procure, store, prepare, distribute, and serve food in long-term care facilities in a safe and sanitary manner. Resources on food safety https://www.foodsafety.gov and https://www.fda.gov/food/fda-food-code/food-code-2017. 

When are Hair Restraints Required?

The surveyor guidance was revised to include that current standards of practice for hair restraints are included in the FDA Food Code (referenced above).  Hair restraints include hairnets, hats, and/or beard restraints to prevent hair from contacting food.

According to the food code, food service staff must wear hairnets when cooking, preparing, or assembling food, such as stirring pots or assembling ingredients of a salad, However, staff are not required to wear hairnets when distributing foods to residents at the dining table(s) or when assisting residents to dine.

When are Gloves Required?

According to the food code, referenced above, gloves are necessary when directly touching ready-to-eat food. Additionally, per infection control guidance, gloves are necessary when serving residents who are on transmission-based precautions.  However, staff do not need to wear gloves when distributing foods to residents at the dining table(s) or when assisting residents to dine, unless touching ready-to-eat foods

• While the information is not revised in the RoPs it is important for providers to ensure whenever staff are using gloves, regardless of the location or task, that staff are following appropriate infection prevention and control measures including performing hand hygiene before applying gloves, with each glove change, and whenever removing gloves upon completion of task.  It is also very important that staff are aware of what they are touching when wearing gloves and ensure that they are not touching potentially contaminated surfaces and then resume touching food without appropriately changing gloves and completing hand hygiene.

Food Distribution and Service:

CMS revised several areas in the food distribution and service sections of F812 to include the importance of maintaining temperatures of food (whether hot or cold) during distribution, which includes to other locations for distribution including other dining rooms and/or resident rooms. In addition to maintaining temperatures for food distribution, staff should also ensure that food is delivered to the residents timely, to ensure food is maintained at the proper temperatures and out of the Danger Zone.

CMS also added examples of food preparation and service problems/risks to avoid including staff distribution of meals without first properly washing their hands and serving food to residents after collecting soiled plates and food waste, without proper hand washing.

What Should Providers do to Ensure Compliance?

• Review policies and procedures related to hair restraints and ensure that the policy accurately reflects when staff are required to wear hairnets. 
• Provide staff training on proper infection control measures for food distribution and service, particularly related to when hair restraints are required, when gloves are required (it would also be a good time to review proper glove use and hand hygiene), and education on food distribution and service ensuring that proper temperatures are maintained to keep food out of the Danger Zone and ensuring that staff are following proper infection prevention and control strategies.
• Providers should complete routine quality assurance monitors of staff completing food preparation, distribution, and service to ensure that staff are safely completing the tasks.  These safety measures would include critical points in the process that could potentially lead to contamination of food as outlined above.

LeadingAge has not released tools for members at this time, however, it is anticipated that a checklist will be developed for providers to use to ensure compliance is met. When tools are released LeadingAge Iowa will post the tools available on our Phase 3 RoP Survey Guidance and Revisions resources website as well as LeadingAge National’s website.