Latest Regulatory Updates from the Centers for Medicare & Medicaid Services (CMS)
In 2019, CMS proposed changing the regulations regarding the qualifications for Directors of Food and Nutrition Services to allow a director to either have two years of experience working in that position, or have completed a minimum course of study in food safety. ANFP, its members, and other organizations submitted comments to CMS in support of keeping the education requirements as originally written in 2016. §483.60 11.28.2016 - In the absence of a full time dietitian, a Director of Food and Nutrition Services was required to be a A) Certified Dietary Manager, Certified Food Protection Professional (CDM, CFPP) B) a Certified Food Manager, C) have a similar certification in food service management and safety, or D) have an Associate's Degree or higher in foodservice management or hospitality.
Fast forward to August 2022, CMS LTC SNFs Final Rule was combined with 2019’s proposed rule, and PPS [CMS-1765-F] 08.03.2022 §483.60 Food and Nutrition Services was posted. An additional educational option was added that was to help with the original 2016 five-year clause that ended under COVID-19 on November 21 that gave those working as the Director prior to 2016 with two years or more experience the opportunity to obtain one of the education options A, B, C or D. Here is the latest 2022 option: E) Has two or more years of experience in the position of Director of Food and Nutrition Services in a nursing facility setting and has, by no later than October 1, 2023, completed a course of study in food safety and management that includes topics integral to managing dietary operations including, but not limited to, foodborne illness, sanitation procedures, and food purchasing/receiving.
The new qualification requirements cannot be met by having taken a course of study alone but must be accompanied by two years of experience as the Director of Food and Nutrition Services.
The good news, that we as ANFP members and CDM, CFPPs can be pleased to see is, the CDM, CFPP credential remains listed first in the regulatory language. Option E has a limited “shelf life” for one year ending October 2023, and like the others B, C, and D, does not have it in their scope of practice to participate in the care planning process. This is another “win” for CDM, CFPPs, yet another compelling reason being a CDM, CFPP makes us a valuable Interdisciplinary Team member in our care communities - because our scope of practice enables us to be a part of the care planning process.
Don’t let this new option distract you! Be proud of the credential you have earned and continue to encourage others to join us and become experts in foodservice management and food safety, and part of the cornerstone of the collaborative food and nutrition profession.
Questions? Reach out to regs@anfponline.org.
Fast forward to August 2022, CMS LTC SNFs Final Rule was combined with 2019’s proposed rule, and PPS [CMS-1765-F] 08.03.2022 §483.60 Food and Nutrition Services was posted. An additional educational option was added that was to help with the original 2016 five-year clause that ended under COVID-19 on November 21 that gave those working as the Director prior to 2016 with two years or more experience the opportunity to obtain one of the education options A, B, C or D. Here is the latest 2022 option: E) Has two or more years of experience in the position of Director of Food and Nutrition Services in a nursing facility setting and has, by no later than October 1, 2023, completed a course of study in food safety and management that includes topics integral to managing dietary operations including, but not limited to, foodborne illness, sanitation procedures, and food purchasing/receiving.
The new qualification requirements cannot be met by having taken a course of study alone but must be accompanied by two years of experience as the Director of Food and Nutrition Services.
The good news, that we as ANFP members and CDM, CFPPs can be pleased to see is, the CDM, CFPP credential remains listed first in the regulatory language. Option E has a limited “shelf life” for one year ending October 2023, and like the others B, C, and D, does not have it in their scope of practice to participate in the care planning process. This is another “win” for CDM, CFPPs, yet another compelling reason being a CDM, CFPP makes us a valuable Interdisciplinary Team member in our care communities - because our scope of practice enables us to be a part of the care planning process.
Don’t let this new option distract you! Be proud of the credential you have earned and continue to encourage others to join us and become experts in foodservice management and food safety, and part of the cornerstone of the collaborative food and nutrition profession.
Questions? Reach out to regs@anfponline.org.