Harmony Healthcare Blog

Requirements for Requirements of Participation (RoP) Overview Phase I, Phase II and Phase III

Posted by Kris Mastrangelo on Tue, Apr 17, 2018


Edited by Kris Mastrangelo

C.A.R.E.

Compliance • Audits/Analysis • Reimbursement/Regulatory • Education/Efficiency


Online Sells - Business Concept. Button on Modern Computer Keyboard. 3D Render.The last few weeks have been a whirlwind with the Harmony Healthcare International (HHI) trainings across the country. The focus is on the phases of the Requirements of Participation as well as the Regulatory and Survey climate. Skilled Nursing Facilities are working diligently to implement the changes.  

The intent of this blog post is to review all phases and associated requirements in a checklist fashion. 

 

Phase I
Requirements for Requirements of Participation (RoP)
Implemented November 28, 2016 

Highlights 

  1. Policies and Procedures
  2. Activities Program
  3. Infection Control Plan
  4. Additional Staff
  5. Resident Continuity
  6. Staff Program Development
  7. Resident Rights Notification
  8. Care Planning and Discharge Planning
  9. Physical Environment

  1. Policies and Procedures
    • Visitation Rights of Residents 483.10(f)
    • Grievance Policy §483.10
    • Use and Storage of Foods brought to Residents by Family/Others §483.60
    • Infection Prevention and Control 483.80
    • Monthly Drug Regimen Review §483.45
      • Except (c)(2) chart review – Phase II
      • (e) Psychotropic Drugs – Phase II
    • Notifying Clinicians 483.50
    • Advance Directives 483.10(b)(8)
    • Bed Hold Policy 483.15
    • Room Changes 483.10(b)(15)
    • Abuse, Neglect and Exploitation of Residents and Property 483.12
    • Permitting Resident to Return to Facility 483.15
    • Admission Policy 483.15(a)
    • Staff Treatment of Residents 483.12(b)1
    • Facility Closure 483.70
    • Administrator’s Duties and Responsibilities 483.70 

  2. Activities Program

  3. Infection Control Plan

  4. Additional Staff
    • Grievance Officer
    • Dietician
      • Dieticians hired before 11.28.16 have 5 years to comply
    • Food Service Directors 483.60(a)(1)(i)
      • Food Service Directors hired before 11.28.16 have 5 years to comply
    • Social Worker

  5. Resident Continuity
    • Discharge Summary
    • Discharge Plan
    • Resident Assessment
    • Drug Regimen Review Report

  6. Staff Program Development 

    Requires an effective training program that facilities must develop, implement, and maintain for all new and existing staff, individuals providing services under a contractual arrangement, and volunteers, consistent with their expected roles.  Training topics must include- 
    • Abuse, Neglect and Exploitation 483.95(c)
    • Nurse Aide Training 483.95(g)(2) and (g)(4)
      • Dementia Management ((g)2)
      • Resident Abuse ((g)2)
      • Care of Cognitively Impaired ((g)4)
  7. Resident Rights Notification
    • Admission
    • Before Transfer or Discharge
    • Orientation about Discharge or Transfer
    • Resident Rights
    • Participating and Updating their Care Planning Process
    • Participating and Updating their Discharge Plan
    • Bed Hold Policy
    • Facility Charges
    • Choosing Their Physician
    • Signing Their Care Plan
    • Significant Change in Mental Health 
      • Notify State Mental Health Authority
    • Abnormal Lab or Radiology Results to Clinician

  8. Care Planning and Discharge Planning
    • Resident Assessment is Person-Centered 483.21 (b)1
    • Person-Centered Goals and Wishes about Care, Activates, and Lifestyle incorporated in Care Plan 483.21 (b)1(iv)
    • Resident’s Preferences for Future Discharge incorporated 483.21 (b)1(iv)
    • Added New Staff to Interdisciplinary Team signing off on Care Plan 483.21 (b)2(ii)
    • Services in the Care Plan are Culturally Competent 483.21 (b)3(iii)
    • Discharge Plan contains all information required in the plan 483.21 (c)
    • Incorporated Resident’s Discharge Goals and Wishes into the resident’s Care Plan 483.21 (c)1(vi)
    • Interdisciplinary Team involved in developing and signing off on discharge care plan 483.21 (c)1(v)
    • Shared Discharge Plan with Resident and Representative 483.21 (b)3(iii) 
    • Month Drug Regimen Review Process 483.45

  9. Physical Environment
    • Inspection of all bed frames, mattresses, bed rails (while resident in bed) as part of regular maintenance program to identify areas of possible entrapment.
    • Bedrooms accommodate no more than two residents 483.90(e)1(i)
      • Only applies to facilities that receive approval of construction or reconstruction or newly certified after 11.28.16
    • Bed is proper size and height for safety and convenience of resident 483.90(e)(2)(i)
    • Bathroom in each room with at least a commode and sink 483.90(f) 

Phase II
Requirements for Requirements of Participation (RoP)
Implemented November 28, 2017 

Highlights 

  1. Contact Information Availability
  2. Reporting Crimes
  3. Transfer and Discharge Documentation
  4. Baseline Care Plan
  5. Staffing and Competencies
  6. Behavioral Health Services
  7. Medical Chart Review and Psychotropic Drugs
  8. Dental Services
  9. Food and Nutrition Services
  10. Facility Assessment
  11. Quality Assurance and Performance Improvement (QAPI)
  12. Infection Preventions and Control Program
  13. Smoking 

  1. Contact Information Availability 
    Providing contact information for:
    • State and Local Advocacy Organizations
    • Medicare and Medicaid Eligibility Information
    • Aging and Disability Resources Center
    • Medicaid Fraud Control Unit 

Information and contact information for State and local advocacy organizations, including but not limited to the State Survey Agency, the State Long-Term Care Ombudsman program (established under section 712 of the Older Americans Act of 1965, as amended 2016 (42 U.S.C 3001 et seq.); and the protection and advocacy system (as designed by the state, and as established under the Developmental Disabilities Assistance and Bill of Rights Act of 2000). 

  • Information regarding Medicare and Medicaid eligibility and coverage
  • Contact information for the Aging and Disability Resource Center or No Wrong Door Program 
  • Contact information for the Medicaid Fraud Control Unit

  1. Reporting Crimes
    The facility must develop and implement written policies and procedures that ensure reporting of crimes occurring in federal-funded long-term care facilities in accordance with section 1150B of the Act. The policies and procedures must include, but are not limited to, the following elements.
     
  • Annually notifying covered individuals, as defined at section 1150B(a)(3) of the Act, of that individual’s obligation to comply with the following reporting requirements. 

Each covered individual shall report to the State Agency and one or more law enforcement entities for the political subdivision in which the facility is located any reasonable suspicion of a crime against any individual who is resident of, or is receiving care from, the facility. 

  • Each covered individual shall report immediately, but not later than 2 hours after forming the suspicion, if the events that cause the suspicion result in serious bodily injury, or not later than 24 hours if the events that cause the suspicion do not result in serious bodily injury.
  • Posting a conspicuous notice of employee rights, as defined at section1150B(d)(3) of the Act.
  • Prohibiting and preventing retaliation, as defined at section 1150B(d)(1) and (2) of the Act. 

  1. Transfer and Discharge Documentation
    When the facility transfers or discharges a resident under any of the circumstances specified in paragraphs (c)(1)(i)(A) through (f) of this section, the facility must ensure that the transfer or discharge in the resident’s medical record and appropriate information is communicated to the receiving health care institution or provider.  


    Documentation in the resident’s medical record must include: 
  • The basis for the transfer per paragraph (c)(1)(i) of this section.
  • In the case of paragraph(c)(1)(i)(A) of this section, the specific resident need(s) that cannot be met, facility attempts to meet the resident needs, and the services available at the receiving facility to meet the need(s).
  • The documentation required by paragraph (c)(2)(i) of this section must be made by
    • The resident’s physician when a transfer or discharge is necessary under paragraph (c)(1)(A) or (B) of this section; and
    • A physician when transfer or discharge is necessary under paragraph (b)(1)(i)(C) or (D) of this section. 
  • Information provided to the receiving provided must include a minimum of the following:
    • Contact information of the practitioner responsible for the care of the resident
    • Resident representative information including contact information.
    • Advance Directive
    • All Special Instructions or Precautions for the ongoing care, as appropriate.
    • Comprehensive Care Plan Goals.
    • All other necessary information, including a copy of the resident’s discharge summary, consistent with 483.21 (c)(2), as applicable, and any other documentation as applicable, to ensure a safe and effective transition of care. 
  1. Baseline Care Plan
    The facility must develop and implement a baseline care plan for each resident that included the instructions needed to provide effective and person-centered care of the resident that meet professional standards of quality care.  The Baseline Care Plan must: 
  • Be developed within 48-Hours of resident’s admission.
  • Include the minimum healthcare information necessary to properly care for the resident including, but not limited to:
    • Initial Goals (Based on admission orders)
    • Physician Orders
    • Dietary Orders
    • Therapy Services
    • Social Services
    • PASARR recommendation, if applicable 

The facility may develop a Comprehensive Care Plan in place of the baseline care plan if the comprehensive care plan: 

  • Is developed within 48 hours of the resident’s admission.
  • Meets the requirements set forth in paragraph (b) of this section (excepting paragraph (b)(2)(i) of this section). 

The facility must provide the resident and their representative with a summary of the baseline care plan that includes but is not limited to: 

  • The initial goals of the resident.
  • A summary of the resident’s medications and dietary instructions.
  • Any services and treatments to be administered by the facility and personnel acting on behalf of the facility.
  • Any updated information based on the details of the comprehensive care plan, as necessary. 

  1. Staffing and Competencies 
    Based on the Facility Assessment for the determination of sufficient number and competencies of staff

    Nursing Services: The facility must have sufficient Nursing Staff with the appropriate competencies and skill sets to provide nursing and related services to assure resident safety and attain or maintain the highest practicable physical, mental, and psychosocial well-being of each resident, as determined by resident assessments and individual plans of care and considering the number, acuity and diagnoses of the facility’s resident population in accordance with the facility assessment required at § 483.70(e). 

    The facility must ensure that licensed nurses have the specific competencies and skill sets necessary to care for resident’s needs, as identified through resident assessments and described in the plan of care.
  1. Behavioral Health Services
  • Each resident must receive and the facility must provide the necessary behavioral health care and services to attain or maintain the highest practicable physical, mental, and psychosocial well-being, in accordance with the comprehensive assessment and plan of care. Behavioral health encompasses a resident’s whole emotional and mental well-being, which includes but is not limited to, the prevention and treatment of mental and substance use disorders.
  • The facility must have a sufficient staff who provide direct services to residents with the appropriate competencies and skills sets to provide nursing and related services to assure resident safety and attain or maintain the highest practicable physical, mental and psychosocial well-being of each resident, as determined by resident assessments and individual plans of care and considering the number, acuity and diagnoses of the facility’s resident population in accordance with §483.70(e). These competencies and skills sets include, but are not limited to, knowledge of and appropriate training and supervision for:
  • Caring for residents with mental and psychosocial disorders, as well as residents with a history of trauma and/or post-traumatic stress disorder, that have been identified in the facility assessment conducted pursuant to §483.70(e), and NOTE: this requirement is implemented in Phase 3. 

Implementing non-pharmacological interventions

Based on the comprehensive assessment of a resident, the facility must ensure that: 

  • A resident who displays or is diagnosed with a mental disorder or psychosocial adjustment difficulty, or who has a history of trauma and/or post-traumatic stress disorder, receives appropriate treatment and services to correct the assessed problem or to attain the highest practicable mental and psychosocial well-being;
  • A resident whose assessment did not reveal or who does not have a diagnosis of a mental or psychosocial adjustment difficulty or a documented history of trauma and/or post-traumatic stress disorder does not display a pattern of decreased social interactions and/or increased withdrawn, angry, or depressive behaviors, unless the resident’s clinical condition demonstrated that development of such a pattern was unavoidable; [Note: (b)(1) and (b)(2) were implemented in Phase 1] and 
  • A resident who displays or is diagnosed with dementia, receives the appropriate treatment and services to attain or maintain his or her highest practicable physical, mental, and psychosocial well-being. 

If Rehabilitative Services, such as, but not limited to physical therapy, speech-language pathology, occupational therapy, and rehabilitative services for mental disorders and intellectual disability, are required in the resident’s comprehensive plan of care, the facility must: 

  • Provide the required services, including specialized rehabilitation services as required in §483.65; or
  • Obtain the required services from an outside resource (in accordance with §483.70(g) of this part) from a Medicare and/or Medicaid provider of specialized rehabilitative services. 

The facility must provide medically-related Social Services to attain or maintain the highest practicable physical, mental, and psychosocial well-being of each resident. [Note: (d) was implemented in Phase 1]. 

  1. Medical Chart Review and Psychotropic Drugs
    Pharmacy Services (Drug Regiment Review) 
  • This review must include a review of the resident’s medical chart.
  • Psychotropic Drugs: Based on a comprehensive assessment of a resident, the facility must ensure that:
    • Residents who have not used psychotropic drugs are not given these drugs unless the medication is necessary to treat a specific condition and diagnosed and documented in the clinical record.
      • Residents who use psychotropic drugs receive gradual dose reductions, and behavioral interventions, unless clinically contraindicated, to discontinue these drugs.
      • Residents do not receive psychotropic drugs pursuant to a PRN order unless that medication is necessary to treat a diagnosed specific condition that is documented in the clinical record; and
      • PRN Orders for psychotropic drugs are limited to 14 days. Except as provided in §483.45(e)(5), if the attending physician or prescribing practitioner believe that it is appropriate to the PRN order to be extended beyond 14 days, he or she should document their rationale in the resident’s medical record and indicate the duration for the PRN order.
        PRN Orders for anti-psychotic drugs are limited it 14 days and cannot be renewed unless the attending physician or prescribing practitioner evaluates the resident for the appropriateness of that medication. 
  1. Dental Services
    Loss or damage of dentures and policy for referral; Referral for dental services regarding loss or damaged dentures §483.55. 
  • Must have a policy identifying those circumstances when the loss or damage of dentures is the facility’s responsibility and may not charge a resident for the loss or damage of dentures determined in accordance with facility policy to be the facility’s responsibility.
  • Must promptly, within 3 days, refer residents with lost or damaged dentures for dental services. If a referral does not occur within 3 days, the facility must provide documentation of what they did to ensure the resident could still eat and drink adequately while awaiting dental services and the extenuating circumstances that led to the delay;
  • For skilled nursing facilities (SNFs)- prohibits SNFs from charging a Medicare resident for the loss or damage of dentures determined in accordance with facility policy to be the facility’s responsibility.
  • For nursing facilities (NFs)- requires NFs to assist residents who are eligible to apply for reimbursement of dental services as an incurred medical expense under the Medicaid state plan.
  • For both SNFs and NFs- clarifies that with regard to a referral for lost or damaged dentures “promptly” means within 3 business days unless there is documentation of extenuating circumstances.
     
  1. Food and Nutrition Services
    As linked to the Facility Assessment.


    Staffing: The facility must employ sufficient staff with the appropriate competencies and skill sets to carry out the functions of the food and nutrition service, taking into consideration resident assessments, individual plans of care and the number, acuity and diagnoses of the facility’s resident population in accordance with the facility assessment required at §483.70(e). 
  1. Facility Assessment

    The facility must conduct and document a facility wide assessment to determine what resources are necessary to care for its residents competently during both day-to-day operations and emergencies.  The facility must review and update that assessment, as necessary, and at least annually.  The facility must also review and update this assessment whenever there is, or the facility plans for, any change that would require substantial modification to any part of this assessment.  The facility assessment must address or include:

The Facility’s resident population, including, but not limited to: 

  • Both the number of residents and the facility’s resident capacity;
  • The care required by the resident population considering the types of diseases, conditions, physical and cognitive disabilities, overall acuity, and other pertinent facts that are present within that population;
  • The staff competencies that are necessary to provide the level and types of care needed for the resident population;
  • The physical environment, equipment, services, and other physical plan considerations that are necessary to care for this population; and any ethnic, cultural, or religious factors that may potentially affect the care provided by the facility, including, but not limited to, activities and food and nutrition services. 

The facility’s resources, including but not limited to: 

  • All buildings and/or other physical structures and vehicles;
  • Equipment (medical and nonmedical);
  • Services provided, such as physical therapy, pharmacy, and specific rehabilitation therapies;
  • All personnel, including managers, staff (both employees and those who provide services under contract), and volunteers, as well as their education and/or training and any competencies relation to resident care;
  • Contacts, memorandums of understanding, or other agreements with third parties to provide services or equipment to the facility during both normal operations and emergencies; and
  • Health information technology resources, such as systems for electronically managing patient records and electronically sharing information with other organizations.
  • A facility-based and community based risk assessment, utilizing an all hazards approach.
     
  1. Quality Assurance and Performance Improvement (QAPI)
  • Initial QAPI Plan must be provided to State Agency Surveyor at Annual Survey §483.75
  • Each LTC facility, including a facility that is part of a multiunit chain, must develop, implement, and maintain an effective, comprehensive, data-driven QAPI Program that focuses on indicators of the outcomes of care and quality of life.
  • The facility must present its QAPI plan the State Survey Agency no later than 1 year after the promulgation of this regulation.
     
  1. Infection Preventions and Control Program
    As linked to Facility Assessment at §483.70(e) and (a)(3) Antibiotic Stewardship §483.80

The facility must establish an Infection Prevention and Control Program (IPCP) that must include, at a minimum, the following elements: 

  • A system for preventing, identifying, reporting, investigating, and controlling infections and communicable diseases for all:
    • Residents
    • Staff
    • Volunteers
    • Visitors
    • Other individuals providing services under a contractual arrangement based upon the facility assessment conducted according to §483.70(e) and following accepted national standards.
  • An Antibiotic Stewardship Program that includes antibiotic use and protocols and a system to monitor antibiotic use.
     
  1. Physical Environment: Smoking
    Establish policies in accordance with applicable Federal, State, and Local Laws and regulations, regarding smoking, smoking areas, and smoking safety that also consider non-smoking residents. 
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Phase III
Requirements for Requirements of Participation (RoP)
Implemented November 28, 2019 

Highlights 

  1. QAPI Plan/Program Governing Body
  2. Person-Centered Care Planning
  3. Trauma Informed Care / Behavioral Health Services for History of Trauma PTSD
  4. Infection Preventionist
  5. Compliance and Ethics Program
  6. Physical Environment
  7. Training Requirements Competencies of Staff
  8. Dietary 

  1. Quality Assurance and Performance Improvement (QAPI) (483.75)
  • Requires all LTC facilities to develop, implement, and maintain an effective comprehensive, data-driven QAPI program that focuses on systems of care, outcomes of care and quality of life.
  • Requires facilities to include mandatory training as a part of their QAPI and infection prevention and control programs that educate staff on the written standards, policies, and procedures for each program.
     
  1. Person-Centered Care Planning Baseline Care Plan requires facilities to develop a baseline care plan for each resident, within 48 hours of their admission, which includes the instructions needed to provide effective and person-centered care that meets professional standards of quality care.
    • PASARR adds a requirement to include as part of a resident’s care plan any specialized services or specialized rehabilitation services the nursing facility will provide as a result of PASARR recommendations. If a facility disagrees with the findings of the PASARR, it must indicate its rationale in the resident’s medical record.
    • Interdisciplinary Team (IDT)
      • Adds a nurse aide, a member of the food and nutrition services staff, and a social worker to the required members of the interdisciplinary team that develops the comprehensive care plan.
      • Requires facilities to provide a written explanation in a resident’s medical record if the participation of the resident and their resident representative is determined to not be practicable for the development of the resident’s care plan. 
    • Discharge Planning
      • The Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT 2014) (Pub. L. 113-185) amended Title XVIII of the Social Security Act by, among other things, adding Section 1899B to the Social Security Act. Section 1899B(i) requires that certain providers, including long term care facilities, take into account, quality, resource use, and other measures to inform and assist with the discharge planning process, while also accounting for the treatment preferences and goals of care of residents.  This section implements the discharge planning requirements mandated by the IMPACT Act by revising, or adding where appropriate, discharge planning requirements for LTC facilities. 
      • Requires facilities to document in a resident’s care plan the resident’s goals for admission, assess the resident’s potential for future discharge, and include discharge planning in the comprehensive care plan, as appropriate.
      • Requires that the resident’s discharge summary include a reconciliation of all discharge medications with the resident’s pre-admission medications (both prescribed and over-the-counter).
      • Adds to the post discharge plan of care a summary of what arrangements have been made for the resident’s follow up care and any post-discharge medical and non-medical services. 
  1. Trauma Informed Care
  • Adds a new section that focuses on the requirement to provide the necessary behavioral health care and services to residents in accordance with their comprehensive assessment and plan of care.
  • Staffing
    • Facility assessment requires facilities to determine their direct care staff needs, based on the facility’s assessment.
    • Competency approach requires that staff must have the appropriate competencies and skills to provide behavioral health care and services, which include caring for residents with mental and psychosocial illnesses and implementing non-pharmacological interventions.
    • Social worker adds “gerontology” to the list of possible human services fields from which a bachelor degree could provide the minimum educational requirement for a social worker. 
  1. Infection Control
  • Require facilities to have a system for preventing, identifying, reporting, investigating, and controlling infections and communicable diseases for all residents, staff, volunteers, visitors, and other individuals providing services under an arrangement based upon its facility and resident assessments that is reviewed and updated annually.
  • Requires facilities to designate an IPCO for whom the IPCP is their major responsibility and who would serve as a member of the facility’s quality assessment and assurance (QAA) committee. Each facility must have an infection prevention and control officer with specialized training; a system of surveillance is required.
     
  1. Compliance and Ethics Program (483.85)
  • Requires the operating organization for each facility to have in operation a compliance and ethics program that has established written compliance and ethics standards, policies and procedures that are capable of reducing the prospect of criminal, civil, and administrative violations in accordance with section 1128I(b) of the Act. 
  1. Physical Environment
  • Call System from each Resident’s Bedside
  • Resident Rooms – requires facilities initially certified after the effective date of this regulation to accommodate no more than two residents in a bedroom.
  • Toilet Facilities – requires facilities initially certified after the effective date of this regulation to have a bathroom equipped with at least a toilet, sink and shower in each room.
  • Smoking – requires facilities to establish policies, in accordance with applicable federal, state and local laws and regulations, regarding smoking, including tobacco cessation, smoking areas and safety.

  1. Training Requirements
  • Requires an effective training program that facilities must develop, implement, and maintain for all new and existing staff, individuals providing services under a contractual arrangement, and volunteers, consistent with their expected roles. Training topics must include-
    • Communication – requires facilities to include effective communications as a mandatory training for direct care personnel.
    • Resident Rights and Facility Responsibilities – requires facilities to ensure that staff members are educated on the rights of the resident and the responsibilities of a facility to properly care for its residents as set forth in the regulations.
    • Abuse, Neglect, and Exploitation – requires facilities, at a minimum, to educate staff on activities that constitute abuse, neglect, exploitation, and misappropriation of resident property, and procedures for reporting these incidents.
    • QAPI & Infection Control – requires facilities to include mandatory training as a part of their QAPI and infection prevention and control programs that educate staff on the written standards, policies, and procedures for each program.
    • Compliance and Ethics – requires the operating organization for each facility to include training as a part of their compliance and ethics program. Requires annual training if the operating organization operates five or more facilities.
    • In-Service training for nurse aides – requires dementia management and resident abuse prevention training to be a part of 12 hours per year in-services training for nurse aides.
    • Behavioral Health training – requires facilities to provide behavioral health training to its entire staff, based on the facility assessment as 483.70(e).
    • Nurse Aide Training on areas of weakness determined by performance reviews and the facility assessment 483.95(g)(3)

 

  1. Dietary
  • Staffing- requires facilities to employ sufficient staff with the appropriate competencies and skills sets to carry out the functions of the dietary service while taking into consideration resident assessments, and individual plans of care, including diagnoses and acuity, as well as the facility’s resident census.
  • Dietitian Qualifications – clarifies that a “qualified dietitian” is one who is registered by the Commission on Dietetic Registration of the Academy of Nutrition and Dietetics or who meets state licensure or certification requirements. For dietitians hired or contracted with prior to the effective date of these regulations, we propose to allow up to 5 years to meet the new requirements. 
  • Director of Food Service- adds to the requirement for the designation of a director of food and nutrition service that the person serving in this position be a certified dietary manager, certified food service manage, or have a certification for food service management and safety from a national certifying body or have an associate’s or higher degree in food service management or hospitality from an accredited institution of higher learning. In states that have established standards for food service managers, this person must meet state requirements for food service managers.
  • Menus and Nutritional Adequacy - adds to the requirements that menus reflect the religious, cultural and ethnic needs and preferences of the residents, be updated periodically, and be reviewed by the facility’s qualified dietitian or other clinically qualified nutrition professional for nutritional adequacy while not limiting the resident’s right to make personal dietary choices.
  • Providing Food and Drink – adds to the requirements that facilities provide food and drink that take into consideration resident allergies, intolerances, and preferences and ensure adequate hydration.
  • Ordering Therapeutic Diets – allows the attending physician to delegate to a registered or licensed dietitian the task of prescribing a resident’s diet, including a therapeutic diet, to the extent allowed by state law.
  • Frequency of Meals – requires facilities to have available suitable and nourishing alternative meals and snacks for residents who want to eat at non-traditional times or outside of scheduled meal times in accordance with the resident’s plan of care.
  • Use of Feeding Assistants – requires that facilities document the clinical need of a feeding assistant and the extent to which dining assistance is needed in the resident’s comprehensive care plan.
  • Food Safety
    • Clarifies that facilities may procure food items obtained directly from local producers and are not prohibited from using produce grown in facility gardens, subject to compliance with applicable safe growing and food handling practices.
    • Clarifies that residents are not prohibited from consuming foods that are not procured by the facility.
    • Requires facilities to have a policy regarding the use and storage of food brought to residents by family and other visitors. 

Harmony Healthcare International (HHI) is available to assist with any questions or concerns that you may have. You can contact us by clicking here.  Looking to train your staff?  Join us in person at one of our our upcoming Competency/Certification Courses.  Click here to see the dates and locations. 


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7th Annual LTPAC Symposium
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