A Look Back at Phase II

How do the New Requirements Impact Staffing?

As of November 28, 2017, newly-hired Food Service Directors must meet the qualifications specified in the regulations and are no longer within the one-year window for obtaining certification. 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.

If you are a Foodservice Manager and were designated as the Director of Food and Nutrition Services prior to November 28, 2016, you may already be eligible to sit for the CDM, CFPP Credentialing Exam. Learn about exam eligibility HERE. These foodservice managers will have until November 28, 2021 to obtain certification.

About Phase II

Phase II went into effect November 28, 2017, and includes revised F-Tags, interpretive guidance for existing requirements and a new computer-based, annual LTC survey process. This new survey process is nationwide, blending both elements of the traditional survey and Quality Indicator Survey processes. Nursing facilities are responsible for demonstrating compliance with the Phase I requirements during their 2017 annual surveys and need to focus on both the Phase I and II requirements in order to avoid the potential for survey deficiencies and negative outcomes. It is important that facilities have a plan to address all the changes outlined in both phases including processes to review current practices to secure effective and efficient adherence to the new standards.

Additional Phase II Focus Areas Include:

• Behavioral Health Services
• Quality Assurance and Performance Improvement - QAPI
• Infection Control - Facility Assessment & Antibiotic Stewardship
• Compliance & Ethics
• Physical Environment - Smoking Policies

CDM, CFPPs need to review these new focus areas to see where food and nutrition services plays a role in helping their facility's team safeguard residents and be compliant with the new regulations.