Dietary, Food and Nutrition Services; Meeting the CMS Hospital and CAH CoPs, DNV Healthcare and TJC Requirements

As per the CMS Guidelines 2021, CMS made 3 changes to the dietary guidelines for hospitals and rewrote all the dietary guidelines for critical access hospitals that went into effect April 1, 2015, with an amendment November 29, 2019. Some hospitals are still working to ensure compliance.

This program will discuss the new CMS Guidelines 2021 or the CMS hospital conditions of participation requirements for dietary and food and nutrition services. It is an important part of the CMS survey and this area has received increased scrutiny of their standards, especially in the area of Infection control.

Following a survey, CMS prepares a list of deficiencies or citations noted during a survey. This program will cover the common deficiencies received by hospitals from CMS in this area.

CMS now permits the Medical Staff and Board to credential and privilege qualified dieticians and qualified nutritional specialists to order the patient’s diet. This includes a therapeutic diet, supplemental feeding, and enteral nutrition. This is also allowed for CAHs including swing beds. CMS has provided additional information about the C&P process for dieticians and this issue will be discussed in detail.

This Joint Commission Food Nutrition Standards program will also cover the Joint Commission provision of care chapter standards related to dietary and the TJC dietary tracer information. The tracer is used to assess and determine the degree of compliance with standards and elements of performance related to nutrition care. The tracer used through dietetic and food services covers some of the same issues discussed during the CMS survey.

This Joint Commission Food Nutrition Standards webinar will discuss the DNV Healthcare dietary standards.

• Discuss that the  Joint Commission  has a tracer for food and dietetic services
• Describe  that CMS has a section on food and nutrition services in the hospital condition of participation standards
• Recall that the Joint Commission provision of care chapter has several standards on dietetic services

CMS Food and Dietetic Services CoP

• Final regulations on credentialing and privileging qualified dieticians and qualified nutritional specialist
  • C&P to order patient diets
  • Can be with or without an appointment to the MS
  • State law and hospital policy
  • State scope of practice
  • Must be C&P by MS and board
• How to obtain a current copy of the CoP manual
• Proposed  changes rea dieticians ordering patient diet
• Ways to keep up with CMS changes
• 3 tag numbers changed and one was deleted (Tag 628, 929, and 630)
• Organized dietary services
• Director and qualified dietary staff required
• Must meet nutritional needs of patients
• Policies required
  • Diet manual availability, frequency of meals served, the system for diet ordering and tray delivery, accommodation of non-routine occurrence, acceptable hygiene practices, kitchen sanitation, etc.
• The director who is full time and qualified
  • List of responsibilities to include in the job description
  • Approve patient menus and nutritional supplements, patient dietary counseling, collaborating with other staff, maintaining patient data to recommend, prescribe, or modify therapeutic diets, etc.
• Dietary policies and procedures
  • Safety practices for food handling, emergency food supplies, orientation, work assignments, menu planning, purchasing of foods and supplies, etc.
• Survey procedure questions
• Diets and menus to meet the needs of patients
• Therapeutic diets and guidelines
• Nutritional needs by recognized dietary practices
• Requirement for a diet order
• Current therapeutic diet manual approved by MS and dietician
• Importance of Infection control in dietary

CAH Dietary Standards

• Dietary standards and 2019 changes
• Credentialing of Dietician
• Dietary services standards

TJC Provision of Care Standards related to Dietary

• Nutritional Screen
• The time frame for screens
• Food and nutrition
• The person responsible for food and nutrition services
• Proper sanitation, temperature, etc of food and nutrition
• What to do if the patient refuses food
• Accommodation of special diets
• Accommodation of ethnic food and nutrition preferences
• Storage of food and nutrition
• Therapeutic diet manual
• Patient education on nutritional interventions, diets, supplements

Topics Discussed Throughout the Patient Tracer Activity

• Assessment, care planning
• Instructions by qualified staff
• Identification and nutrition risk
• Nutrition screening criteria
• Time frames for nutrition assessment and re-evaluation
• Measuring food consumption
• The special population needs such as NPO, on vents, in isolation, getting hyperalimentation
• Procedure to follow if the patient refuses meals
• Discharge education and referrals
• Communications between dieticians and food services

Dietary and food services day-to-day operation information

• Director of dietary qualifications
• Responsibilities of dietary and food services leaders
• Emergency/disaster plans
• Hospital diets and menus
• Food preparation and storage
• Safe food handling and health of food service staff
• Contracts for services, food, nutrition support supplies, and formulas
• Sanitation and infection control (pest control, chemicals)
• Quality improvement activities etc.

DNV Healthcare Standards

Professional Organization Position Statements

• Dieticians
• Director of dietary
• Dietary staff
• Joint Commission liaison or accreditation director DNV Healthcare
• CMS or regulatory staff
• Compliance officer
• Chief Operating Officer
• Chief Nursing Officer
• Nurses and nurse managers
• Nurse educator
• Chief Medical Officer
• Medical staff  and MS department staff
• Anyone else responsible for complying with the CMS, DNV Healthcare, or Joint Commission standards that affect dietary and nutrition services