On July 16, 2019, CMS posted a document of PROPOSED changes to the Long Term Care CoP's Conditions of Participation/Medicare and Medicaid Programs Requirements for Long Term Care Facilities.

One item CMS is proposing changes to is the education requirement for Director of Food and Nutrition Services. Their rationale is because stakeholders are "concerned about a workforce shortage of certified dietary managers and the financial costs imposed on existing experienced staff to obtain specialized training".

CMS acknowledges that set standards for the person leading the department is important, and are putting forth suggestions for how to better reduce the burden by revising the standards to increase flexibility, the specifics being that a minimum standard be set.

It is important for everyone to understand that the current rules are still in effect and this is only a proposal that is open for comments. Once the comment period is over, CMS will review and thoroughly vet them before any decisions and rule changes will be made. This is a common political process.

As we indicated early on, ANFP has thoroughly vetted this proposal and prepared the attached comments to help maintain the standards of our CDM, CFPP credential. We have submitted these comments, on behalf of all our members, to maintain the integrity of the credential in the CMS PROPOSED rule making.

Access the Comments