Phase I


A Look Back at Phase I

On September 28, 2016, the Centers for Medicare & Medicaid Services (CMS) issued its final regulations of Part 483 to Title 42 of the Code of Federal Regulations, the requirements for states and long-term care facilities.

Why is this important and how did it impact CDM, CFPPs?

Phase I of the revised nursing home regulations went into effect November 28, 2016. Five regulatory sections were fully implemented in this phase. They included:

  1. Resident Assessment
  2. Quality of Life
  3. Physician Services
  4. Laboratory, radiology, and other diagnostic services, and
  5. Specialized Rehabilitation.

Additions to §483.60 Food and Nutrition Services Include:

  • Continues food and nutrition protections - food safety
  • Qualified food and nutrition services staff - sufficient and competent
  • Reasonable efforts to address religious, cultural, and ethnic needs
  • Frequency of meals - snacks
  • Policy regarding use and storage of foods
  • Updated educational requirements (dietitian and food service manager)

In Section §483.60 Food and Nutrition Services, several highlights are significant to the CDM, CFPP credential.

How did the New Regulations Impact Food and Nutrition Services?

In Section §483.60 Food and Nutrition Services, the following highlights are significant:

• The Certified Dietary Manager, Certified Food Protection Professional (CDM, CFPP) credential is now listed as the primary qualification for the Director of Food and Nutrition Services in the absence of a full-time dietitian.

• A representative from the Food and Nutrition Services department must be included on the Interdisciplinary Team (IDT). The CDM, CFPP is the only credential listed in addition to the Registered Dietitian Nutritionist that is qualified to participate as defined by scopes of practice. A scope of practice is a critical component in defining the role of any credentialed professional. View the CDM, CFPP Scope of Practice HERE.

• While CMS lists the CDM, CFPP credential as the primary qualification for the Director of Food and Nutrition Services, the regulations also acknowledge state requirements for staffing qualifications. Currently, the CDM, CFPP meets requirements in 21 states. View the list of states HERE.

• CMS also posted two additional documents that are important to CDM, CFPPs.

•Updated List: Federal Regulatory Groups for Long-Term Care Facilities (click HERE to view)
•Phase II Tag Crosswalk – Click HERE to see which F-Tag changes are relevant to CDM, CFPPS
•For the full list of F-Tag changes, click HERE.

How did the New Requirements Impact Staffing?

According to the requirements, individuals who were currently employed as the designated Director of Food and Nutrition Services prior to November 28, 2016 would have until November 28, 2021 to meet the staffing requirements outlined by CMS. These individuals must now meet these staffing requirements. Individuals hired between November 28, 2016 and November 28, 2017 had a one-year window to meet these staffing requirements. This is no longer valid for new Foodservice Directors hired after November 28, 2017.

Current foodservice managers may already be eligible to sit for the CBDM Credentialing Exam. Learn about exam eligibility HERE.