Transcript Slide 1

Iowa Dietetics in Healthcare
Food and Nutrition Services and the
State Survey Process
April 8, 2013
Sandra Frahm RD, LD
Health Facilities Surveyor
[email protected]
• Licensure – mandatory for Iowa facilities; the
type of license determines which chapter of
the Iowa Administrative Code applies.
• Hospitals - Chapter 51
• Nursing Facilities - Chapter 58
• Accreditation – A hospital/Critical Access Hospital
(CAH) accredited by Joint Commission, American
Osteopathic Association (Health Facilities
Accreditation Program) or Det Norske Veritas
Healthcare (DNV) is considered “deemed” to
meet applicable Federal regulations (CMS) and
not subject to the routine survey schedule.
Accreditation is optional. There is no accrediting
organization approved for long term care.
• Certification – A recommendation by the State
Agency (DIA) on the compliance of a provider
with the conditions of participation,
requirements and/or conditions of coverage
and refers to Federal certification to receive
Medicare/Medicaid funds.
Conditions of Participation and
Conditions for Coverage
• Developed by Centers for Medicare and
Medicaid Services (CMS)
• Health care organizations must meet in order
to begin and continue participating in the
Medicare and Medicaid programs.
Survey Process
• Resident-Centered – based on investigation of
the care and services provided to meet the
individual needs and preferences of the
sample residents
• Outcome-Oriented – look at actual and
potential for negative outcomes and failure by
the facility to help residents achieve their
highest practicable level of well-being.
• Focus is to determine whether the facility is
actually providing services rather than whether
the facility is capable of providing them and starts
with observations.
• The survey assesses compliance with residents’
rights and quality of life requirements, accuracy
of residents’ comprehensive assessments and the
adequacy of care plans based on those
assessments, the quality of care and services
provided and the effectiveness of the physical
environment to accommodate residents needs
and maintain safety.
• Statement of deficiencies – Form CMS-2567
• Includes the federal survey tags:
Nursing facilities – F tags
Critical Access Hospitals – C tags
Acute Hospitals – A tags
Serves as the basis for the plan of correction
which must identify how it will correct the
deficiencies identified.
Survey and Certification Letters
(S& C Letters)
• Guidance, clarifications and instructions to
State Survey Agencies and CMS Regional
• May simply provide clarification of an existing
federal tag
• May accompany a new or revised tag with an
explanation and instructions
S&C: 12-46-NH
• Released September 27, 2012
• Revisions to Interpretive Guidance at F tag 322
– Tube feedings
• F tag 321 is deleted and the regulatory
language and guidance moved to F tag 322.
S&C: 13-02-NH
• Released November 2, 2012
• Clarification of Guidance related to
Medication Errors and Pharmacy Services
• Includes clarification and guidance regarding
the administration of medications via a
feeding tube, along with other medication
related issues.
• The majority of others released in 2012 do not
directly address nutrition or dietary related
activities, but some may apply indirectly with
topics including quality, dementia care, MDS
3.0 revisions, advanced directives and
infection control (related to laundry).
Top 10 deficiencies in SNF/NF
1/1/12 thru 12/31/12
• F323 – Free of accident, hazards, supervision
• F441 – Infection control (186)
• F281 – Services provided meet professional
standards (183)
• F312 – ADL care provided for dependent
residents (161)
• F371 – Food procure, store, prepare, serve
Top 10 deficiencies in SNF/NF
• F309 – Provide care/services for highest well
being (129)
• F363 – Menus meet resident needs, menus
prepared in advance and followed (75)
• F465 – Safe, functional, sanitary, comfortable
environment (74)
• F314 – Treatment/services to prevent/heal
pressure sores (59)
• 315 – No catheter, Prevent UTI (58)
Additional Dietary/Nutrition TAGS
• F325 – Nutrition – Based on a resident’s
comprehensive assessment, the facility must
ensure that a resident maintains acceptable
parameters of nutritional status, such as body
weight and protein levels, unless the
resident’s clinical condition demonstrates that
this is not possible and receives a therapeutic
diet when there is a nutrition problem. (19)
• F360 - Dietary Services – the facility must
provide each resident with a nourishing,
palatable, well-balanced diet that meets the
daily nutritional and special dietary needs of
each resident. (1)
• F361 – Staffing: the facility must employ a
qualified dietitian either full-time, part-time,
or on a consultant basis.
• F362 – Standard Sufficient Staff – adequate
support personnel to carry out department
functions. (4)
• F364 – Food : Each resident receives and the
facility provides: food prepared by methods
that conserve nutritive value, flavor, and
appearances; Food that is palatable,
attractive, and at the proper temperature (20)
• F365 – Food prepared in a form designed to
meet individual needs. (7)
• F366 - Substitutes offered of similar nutritive
value to residents who refuse food served. (1)
• F367 – Therapeutic Diets: therapeutic diets
must be prescribed by the attending
physician. (4)
• F368 – Frequency of meals: the facility
provides at least three meals daily, at regular
times comparable to normal mealtimes in the
community, no more than 14 hours between a
substantial evening meal and breakfast the
following day unless a nourishing snack is
provided at bedtime, must offer snacks at
bedtime daily (20)
• F369 - Assistive Devices - The facility must
provide special eating equipment and utensils
for residents who need them. (1)
Top 10 deficiencies in Critical Access
• C278 – Patient care policies – A system for
identifying, reporting, investigating, and controlling
infections and communicable diseases of patients
and personnel. (7) This is the area where kitchen
sanitation/food safety issues are citied.
• C276 – Patient care policies: rules for the storage,
handling, dispensation, and administration of drugs
and biologicals. (6)
• 2400 – Compliance with 489.24; Special
Responsibilities of Medicare Hospitals in Emergency
Cases (6)
• C308 – Protection of record information (5)
• C222 – Maintenance – essential mechanical,
electrical, and patient-care equipment is maintained
in safe operating condition (3)
• C340 – Quality assurance – the quality and
appropriateness of the diagnosis and treatment
furnished by doctors of medicine or osteopathy are
evaluated (3)
• 2406 – Medical Screening Exam (Emergency Rooms)
• C229 – Emergency Procedures – Providing for an
emergency fuel and water supply (2)
• C241 – Governing body – related to the
determination, implementation and monitoring the
polices governing the CAH’s total operation. (10)
• C259 – Responsibilities of MD or DO; In conjunction
with the physician assistant and/or nurse practitioner
members, periodically reviews the patient records,
provides medical orders, and provides medical care
services to patients. (2)
• State Operations Manual
- Appendix A – hospitals
- Appendix P and PP – Long term care
- Appendix W – Critical Access Hospital
• Appendix PP
• Appendix W
• Appendix A
• Survey and Certification Letters web site:
• Training Tools
Iowa Administrative Code
• Chapter 51 – hospitals
• Chapter 58 – nursing facilities
• Department of Inspections and Appeals
US Food and Drug Administration Food
• Chapter 51 – refers to the 2005 version
• Chapter 58 – refers to the 1999 version
• 2009 version