Finding Description
Based on observation, interview, and record review, the facility failed to employ sufficient staff with the appropriate competencies and skills sets to carry out the functions of the food and nutrition service when the Director of Food and Nutrition Services (referred to as Director of Dining Services (DDS)), albeit was a full time (FT) position, DDS was responsible for not only the main kitchen that provided foodservice for the residents residing in the Health Center (skilled nursing facility), but also responsible for two other foodservice operations located on the Continuing Care Retirement Community (CCRC) campus, community Meals on Wheels, and providing food for another contracted small health facility. DDS failed to demonstrate appropriate skill set related to sufficient managerial monitoring and guidance related to: 1a. TCS foods (Time Temperature Control for Safety - food that requires time-temperature control to prevent the growth of bacteria) were not consistently and accurately cooled down to ensure food safety; 1b. An ice machine was not sanitary; 1c. Incomplete cleaning schedules and missed orientation and competency check for an employee; and 1d. Other unsanitary conditions such as clean foodservice equipment stored on unclean shelves, leaking pipes located in the dish washing areas, and there were rodent bait stations located in the dry food storage room in which the rodent bait was not contained in a covered, tamper-resistant bait station.
This was further compacted by facility failing to ensure effective management and organization of the food and nutrition services department when there lacked frequently scheduled consultation by a Registered Dietitian (RD) to the Certified Dietary Manager/DDS to lend RD expertise by identifying system issues to include unsafe food handling and sanitation practices and ensuring development of prompt action plan to resolve the issues for the health and safety of the residents.
As a result of unsanitary conditions and unsafe food handling practices 56 residents residing in the Health Center (SNF) receiving food from the main kitchen were placed at an increased risk for foodborne illness. (Cross Reference F812)
2. Registered Dietitian (RD) 1 and Corporate Registered Dietitian (CRD) failed to demonstrate appropriate skill set to carry out the functions of the food and nutrition service when RD 1 and CRD did not identify and communicate to leadership that an obsolete therapeutic diet NCS (No Concentrated Sweets) was being implemented for diabetes care for residents. There were eight residents residing at the facility with a therapeutic diet order for NCS as follows: Resident #51, Resident #1, Resident #45, Resident# 17, Resident #30, Resident #43, Resident # 26, and Resident # 9.
As a result, the RDs failed to utilize their expertise in the development of resident care policies and procedures to ensure that the facility provides care and services in accordance with current standards of practice to provide clinical and technical direction to meet the nutritional needs of residents with diabetes.
Findings:
1. During the annual recertification survey from 1/07/25-1/10/25, multiple issues surrounding the delivery of dietetic services were unmet in relation to:
1a. During an observation on 01/07/25 at 09:39 a.m., inside the walk -in refrigerator in the kitchen, there was cooked macaroni style pasta, stored in a large, deep container, labeled as prepared on 01/07/25 for soup and use by 1/9/25. DSS confirmed the soup would be served to residents.
During an observation on 01/07/25 at 09:57 a.m. inside the walk-in refrigerator in the kitchen, a large pan size of 4 (inch) deep of cooked quinoa labeled as Prepped Salad, prepared on 1-6-25 at 6:23 p.m., and Use By 1-10-25 at 6:23 p.m., and another large 4 pan of cooked plain quinoa labeled as cooked on 1-6-25 at 6:23 pm an Use By 1-10-25 at 6:23 pm. DSS stated the quinoa would be served to residents as a cold salad.
During a concurrent observation and interview on 01/07/25 at 10:20 a.m., with Lead [NAME] (LC) 2, in the kitchen, there was a cool down log posted on the wall with one entry made on 01/02/25 for penne pasta. LC2 confirmed the only entry on the cool down log was on 01/02/25.
During a concurrent observation and interview on 01/07/25 at 10:23 a.m., with DDS and LC2, in the kitchen, LC2 said he cooked the macaroni pasta that morning at 05:45 a.m. and placed it on a 2 (inch) sheet pan to chill. Two hours later he checked the temperature, and it was 53 degrees F (Fahrenheit). He checked the temperature again 2 hours later (4 hours from the time it was cooked) and the temperature was 38 degrees F. LC2 stated he did not document the cool down temperatures on the cool down log. LC2 was asked to check the temperature of the cooked macaroni pasta and the temperature read from the digital thermometer was 74 degrees F. LC2 calibrated the thermometer in ice water to 32 degrees F, and stirred the pasta and then re-checked the pasta temperature, and it read 67.8 degrees F.
During a concurrent observation and interview on 01/07/25 at 3:20 p.m., with DDS in the walk-in refrigerator, the same macaroni pasta from the morning remained available for use. DDS verified it was the same macaroni pasta that had a temperature (temp) of 67.8 degrees nearly 5 hours after the initial cool down. DDS was asked to get the cool down log for further discussion of the events of the morning, in the presence of Sous Chef (SC). The cool down log now showed the macaroni pasta was 53 degrees F at 5:45 a.m. on 1/07/25 and two hours later being 38 degrees F. DDS was asked what he thought about the documentation. DDS stated he was unaware that LC 2 documented that on the cooling log after surveyors left the kitchen in the morning. DDS was asked if the information documented was accurate and he stated he would not know without speaking to LC 2 because he did not know if LC 2 further cooled down the macaroni pasta, on ice for example, after the temperature was observed to read 67.8 degrees F. After further discussion, DDS confirmed he observed the temperature reading of 67.8 degrees F for the macaroni pasta close to 5 hours after the initial cooling began and was unable to explain why the cooling log indicated it was 38 degrees F. DDS verified that toxin formation could occur if the initial 2 hour cool did not achieve a temperature of 70 degrees F or less, and that even a TCS food reached 41 degrees F or less in an additional 4 more hours the food may still be unsafe since toxins are heat-resistant. DDS acknowledged he had not taken immediate corrective action to direct staff to throw out the macaroni pasta since he was unable to verify it was cooled down safely, after it was identified five hours earlier in the day at 10:23 a.m., and may cause the highly susceptible residents to get foodborne illness.
During a concurrent observation and interview on 01/07/25 at 3:32 p.m., with DDS in the walk-in refrigerator, the same pan of cooked quinoa in which the DDS was aware was not documented as being cooled down safely on the cool down log, was now prepared into a Moroccan Quinoa Beet Salad on the resident's select menu for lunch and dinner on 01/8/25. DDS verified quinoa was a TCS food that would need to be cooled down per established professional standards for food safety. DDS stated he was not able to verify the Quinoa Beet Salad was safe to serve as there was no documentation of the cool down process on the cool down log and stated it should be thrown out, however, this was identified five hours earlier without immediate corrective action during which time the kitchen staff further prepared the plain quinoa into a beet salad.
During an interview on 01/08/25 at 11:16 a.m. with DDS, DDS stated the Registered Dietitian (RD) 1 had input on menus, otherwise RD was mainly clinical nutrition care. DDS stated, RD 1 walked through the kitchen on occasion but not on a scheduled, formalized, routine basis. DSS stated that was one of his upcoming plans was to get himself, the Executive Chef that was hired one month ago and RD 1 on a routine formalized schedule to conduct audits of food safety and sanitation, among other agenda items.
During a review of the FDA Food Code Annex (FDAFCA), dated 2022, the FDAFCA indicated, Excessive time for cooling of time/temperature control for safety foods has been consistently identified as one of the leading contributing factors to foodborne illness. During slow cooling, time/temperature control for safety foods are subject to the growth of a variety of pathogenic microorganisms. A longer time near ideal bacterial incubation temperatures, 70o [degrees]F - 125oF), is to be avoided. If the food is not cooled in accordance with this Code requirement, pathogens may grow to sufficient numbers to cause foodborne illness.Safe cooling requires removing heat from food quickly enough to prevent microbial growth. The Food Code provision for cooling provides for cooling from 135ºF to 41°F.in 6 hours, with cooling from 135ºF to 70°F in 2 hours.The initial 2-hour cool is a critical element of this cooling process. Conversely, if cooling from 135ºF to 41°F.is achieved in 6 hours, but the initial cooling to 70ºF took 3 hours, the food safety hazards may not be adequately controlled.
During a concurrent interview and record review on 01/08/25 at 12:37 p.m. with DDS, DDS stated he had the cooks make a new batch of quinoa yesterday on 01/07/25 in the afternoon, and he verified the cool down process was done correctly. The Cooling Log (CL), dated 01/07/25, indicated the initial cooling process began at 4:30 at 191 degrees F and was 66 degrees F 2 hours later at 6:30 and at 9:00 the quinoa was 38 degrees F, initialed by a lead cook (LC) 3 as AA. DDS verified only the cook position cools down food. DDS was asked what time the cooks go home and he stated between 7:30 p.m. to 8:00 p.m. DDS was asked if 9:00 meant 9:00 a.m., and DDS stated, he did not know, maybe AA (LC 3) stayed later. DDS stated, I don't know and she is on vacation for the rest of the week.
During a review of LC 3's Employee Timecards (ETC), dated Tues 1/07, the ETC indicated LC 3 clocked out of work at 7:20 p.m.
During a review of the facility's policy and procedure (P&P) titled, Food Handling Guidelines (HACCP), dated 01/2025, the P&P indicated, Cooling of potentially hazardous cooked foods: Food shall be cooled from 135F to 70F as measured at its center within two hours from 70F to 41F within an additional four hours for a total cooling time of six hours or less. Use the Cooling Log form .to document the temperature of the food at the following times: when placed in cooling equipment, and then at 2 hours and 6 hours after placing in cooling equipment. Foods that have not cooled to 70 degrees F within 2 hours of being placed in the cooling equipment: reheat once to 165 degrees F and re-cool.Food that is not below 41 degrees F at 6 hours must be discarded.
During a review of the FDA Food Code (FDAFC), dated 2022, the FDAFC indicated, The person in charge shall ensure that employees are using proper methods to rapidly cool time/temperature control for safety foods that are not held hot or are not for consumption within 4 hours, through daily oversight of the employees' routine monitoring of food temperatures during cooling.
During an interview on 01/10/25 at 2:40 p.m. with RD 1, in the presence of DDS, RD 1 stated she has been employed at the facility for three months. RD 1 stated she had completed a sanitation and food safety audit of the kitchen soon after hire for learning of her new job duties. RD 1 stated at that time, she had identified incomplete documentation of cool down but had not had followed up as of yet.
1b. During an interview on 01/07/25 at 10:51 a.m. with DDS, DDS stated ice obtained from an ice machine located in a pantry adjacent to nursing station 1 was used in the dining room located at the health center (SNF) for residents.
During an interview on 01/09/25 at 10:06 a.m. with LN 1 at nursing station one, LN 1 stated, the ice machine in the pantry was used for residents water pitchers to provide ice water for hydration.
During a concurrent observation and interview on 01/09/25 at 10:45 a.m. with DDS and Maintenance Supervisor (MS) in the nurse's station pantry room, DDS observed the ice-machine with thick build-up of white and blackish/brownish colored substance where the ice and water dispenser chutes get secured in place. DDS stated it looked like hard water deposits and without swabbing and culturing the area, the dark spots look like mold. DDS acknowledged the dispenser chutes did not look sanitary. DDS and MS verified that neither kitchen staff nor maintenance staff had a role in cleaning of the ice-machine located in the nurse's station pantry room in between the outside contracted vendor that cleans the machine on a semi-annual basis.
During a concurrent interview and record review on 01/10/25 at 2:30 p.m. with DDS, the main kitchen's Ice Machine Cleaning Log (IMCL), dated 2024 was reviewed. The IMCL indicated, Bi-annual services provided by outside vendor. Monthly cleaning instructions by Nutrition when not serviced by maintenance; 1. Empty out all ice, 2. Sanitize and wipe down inside of bin/machine, 3. Sanitize and wipe down ice chute, 4. Wipe down exterior of machine. DDS verified that system for the ice machine located in the kitchen kept that ice-machine in a sanitary condition. DDS acknowledged ice was food and even though the facility had not assigned in between cleaning to the food and nutrition services department that he could have lend his knowledge and advice as a Certified Dietary Manager to the facility leadership as the facility was a whole unit versus departmentalization.
1c. During a concurrent observation and interview on 01/07/25 at 09:39 a.m., with DDS in the dry food storage area, a kitchen staff titled Porter (PO) was observed sweeping. There was an extensive quantity of debris observed on the floor behind, and under, metal racks. PO stated the dry food storage room was to be swept and mopped one time a day. PO stated there was not a log or requirement for him to sign or initial anywhere after he completed the task.
During a concurrent interview and record review on 01/07/25 at 03:37 p.m. with DDS in the kitchen, DDS reviewed the Master Cleaning Schedule, dated 1/5/25, that indicated the floors were to be cleaned on Monday (1/6/25) and on Friday (1/10/25). DDS stated the cleaning of the floor task was missed on 1/6/25 as it was expected for staff to initial once the task was completed.
During a review of the facility's job description titled Cook that was provided for PO, the JD was signed by PO on 8/23/24.
During a concurrent interview and record review on 01/10/25 at 2:40 p.m. with DDS, DDS was asked if he conducted orientation training and/or competency evaluation upon hire for PO. DDS stated he had a signed job description but did not have My First 5 on file which was a list of job duties specific to the employee's job title to go over with new staff on their first 5 days of employment. DDS stated, it was missed.
During a review of the facility's policy and procedure (P&P) titled, Orientation and Education; On-The-Job Training, dated 1/25, the P&P indicated, Policies: On-the-job training is implemented for the purpose of: Task-related training of new associates; Retraining for different/additional position(s); Correcting deficiencies in job skills for current position.Improving a function identified through performance improvement process or evaluation. Procedures: .Evidence of training to ensure competency in the new role is available in the associate's personnel file.
During a concurrent observation and interview on 01/08/25 at 11:11 a.m., with DDS in the kitchen near the stove range, observed a floor sink (drain), and the floor located by the floor sink, with buildup of black grime and dried food debris. DDS stated it was not sanitary.
During a review of the Master Cleaning Schedule (MCS), dated 1/5/25, the MCS indicated the Drains were to be cleaned on 1/5/25 and on 1/7/25, the initial column for both days was blank.
During a concurrent observation and interview on 01/08/25 at 11:14 a.m., with DDS in the kitchen, clean food preparation equipment, such as pots, food holding pans, pitchers were stored directly on shelving that had a buildup of black grime. In addition, there was a worn and discolored pitcher, and a pan with deep scratches that was no longer a smooth cleanable surface. DDS stated the clean dishes were not stored in a sanitary manner. DDS verified some of the foodservice equipment needed to be replaced.
During an interview on 1/08/25 at 10:55 a.m. with DDS, DDS stated he was the person responsible for the entire food service operation including the day to day operations to ensure food safety and sanitation of the main kitchen and the health center (SNF). DDS stated due to the size of foodservice operations that occurs at multiple locations on the CCRC campus he relied heavily on the Executive Chef and Sous Chef for monitoring, identifying and reporting to him any concerns.
1d. During the recertification survey from 01/07/25 to 01/10/25 there were further unsanitary conditions related to clean foodservice equipment stored on unclean shelves in the kitchen, leaking pipes located in the 3-compartment sink room and in the dishmachine room, and multiple rat traps located in the dry food storage room of the kitchen in which the rodent bait was not contained in a covered, tamper-resistant bait station as required by the FDA Food Code, dated 2022.
During an interview on 01/10/25 from 2:20 to 3:00 p.m. with DDS, in the presence of RD 1, DDS verified the above findings and again stated that he was the person responsible for the daily operations of the foodservice to ensure food safety and sanitation from the time the food arrived to the CCRC to the time it was served to residents in the Health Center (SNF). DDS stated he delegated a lot of tasks to the Executive Chef (EC) and needed to rely on him heavily for daily oversight of staff and implementation of facility's policies and procedures and for EC to identify and report to him any concerns that need to be addressed within the entire foodservice operation. DDS stated he was in the kitchen daily and conducted daily briefings with kitchen staff and with a Dining Services Manager, and a Nutrition Care Supervisor, however, the CCRC foodservice operation was extensive as the non-SNF licensed premise also had multiple eating areas with kitchens and other kitchen staff.
During a review of the facility's job description titled, Director of Dining Services, undated, the JD indicated, Leading Food & Beverage Operation: .Ability to quickly evaluate personnel, operations, and culinary situations and make appropriate recommendations to person(s) involved.Perform daily walk-through to ensure full compliance with Department of Health regulations and [name of contracted services] Group standards. Directs and conducts safety, sanitation, and maintenance programs. Ensures that regular, ongoing communication occurs in all areas of food and beverage by leading pre-meal briefings and staff meetings. Advise and update the executives, supervisors, co-workers, and subordinates on relevant information in a timely manner by telephone, in written form, e-mail, or in person.establish goals including performance goals.Identifies the developmental needs of others, coach, and mentor team members by providing feedback and training to achieve performance objectives.
2. During an observation on 01/08/25 at 11:46 a.m. in the dining room, Resident 43's meal tray ticket (MTT) indicated, Texture: Regular, Special Diets: NCS [no concentrated sweets], Vegetarian Lacto-Ovo [eats dairy products and eggs but not meat], Alerts: 1/2 portion of dessert, No Concentrated
Sweets.
During a review of Resident 43's admission Record (AR), dated 06/13/2023, the AR indicated, Resident 43 had Type 2 Diabetes Mellitus.
During a review of Resident 43's Order Details (OD), dated 7/22/2024, the OD indicated, Diet Type: No Concentrated Sweets (NCS).
During a concurrent observation and interview on 01/08/25 at 11:48 a.m. with Registered Dietitian (RD) 1 in the dining room where dining staff were plating Resident 30's lunch plate from a steamtable, Resident 30's MTT was reviewed. RD 1 stated Resident 30 was not served dessert because he did not want dessert today as he filled out his own select menu.
During a review of Resident 30's admission Record (AR), dated 07/22/2024, the AR indicated, Resident 30 had Type 2 Diabetes Mellitus.
During a review of Resident 30's Order Details (OD), dated 7/22/2024, the OD indicated, Diet Type: No Concentrated Sweets (NCS).
During a concurrent interview and record review on 01/08/25 at 11:48 a.m. with RD 1 in the dining room, RD 1 reviewed the planned menu that included a column titled CCD. RD 1 stated CCD meant consistent carbohydrate diet, but the facility treated the CCD diet as a NCS diet. RD 1 stated the doctor's order NCS diets for residents with diabetes in the medical record, not CCD diets. RD 1 stated the kitchen staff are trained to serve the NCS diet order by serving ½ portion of dessert that was planned for the regular (non-therapeutic) diet, when the resident select's dessert from their select menu. RD 1 reviewed the lunch menu under the column CCD that listed Same as Base; 1 carb [carbohydrate] and RD 1 stated that meant Chocolate Mousse; ½ cup or for the Snickerdoodles [cookies] 1 [one] each should have been served the same way the regular diet would have received the dessert if the menu was followed. RD 1 stated the planned menu was not followed because the facility's diabetic diet was NCS and not CCD.
During a concurrent interview and record review on 01/09/25 at 3:45 p.m. with RD 1 and Corporate Registered Dietitian (CRD), the facility's diet manual, approved on 6/17/24 and 1/10/25, titled Indiana Diet Manual incorporated a link to also include the NCM (Nutrition Care Manual) from AND (Academy of Nutrition and Dietetics) into the facility's approved diet manual per CRD. A policy and procedure on Diet Manual was requested but was not provided.
During an interview on 01/09/25 at 4:00 p.m. with RD 1 and Corporate Registered Dietitian (CRD), RD 1 and CRD both stated the only diabetic diet that was used at the facility was NCS. Both RD 1 and CRD were unaware the NCS diet was no longer recognized as a therapeutic diet for the care of diabetes. Both RD 1 and CRD were asked to review obsolete (out-of-date) diet orders listed in their facility's diet manual portion from the NCM and determine as to whether the facility was implementing therapeutic diet for diabetes care in accordance with established standards of practice.
During a review of a document titled CCD/No Concentrated Sweets (NCS) provided by the facility from the facility's Indiana Diet Manual, the CCD/,NCS indicated, How to order the diet: Order as No Concentrated Sweets (NCS) diet.References: Acad Nutr Diet. [Academy of Nutrition & Dietetics] 2012.
During a review of the Academy of Nutrition and Dietetics current Nutrition Care Manual (NCM), dated 2025, the NCM indicated, Use of the noted obsolete terms and associated recommendations should be avoided. Obsolete diets and diet terminology for condition Type 1 Diabetes and Type 2 Diabetes: No Concentrated Sweets diet, No Sugar Added, Low Sugar, Liberal Diabetic Diet.With regard to the no concentrated sweets, no sugar added, low sugar, and liberal diabetic diets.None of these approaches to food and meal planning is appropriate because each unnecessarily restricts sucrose.
According to the facility's Diet Type Report (DTR), dated 1/10/25, DTR indicated there were eight residents residing at the facility with a NCS diet order as follows: Resident #51, Resident #1, Resident #45, Resident# 17, Resident #30, Resident #43, Resident # 26, and Resident # 9.
During an interview on 01/09/25 at 04:15 p.m. with RD 1 and CRD, CRD stated she would work on changing the facility's system related to using NCS diets and practices to care for residents with diabetes.
During a review of the Academy of Nutrition and Dietetics current Nutrition Care Manual (NCM), dated 2025, the NCM indicated, The name of the diet used in your facility should no longer emphasize the restriction of sugar or sweets but rather emphasize consistent carbohydrates. No foods are omitted from the consistent carbohydrate meal plan unless required by a comorbidity [presence of two or more diseases or conditions]. A consistent carbohydrate diet requires initial and ongoing collaborative planning with the patient to incorporate their individualized goals, preferences, and any comorbidities.
During a review of Management of Diabetes in Longterm Care and Skilled Nursing Facilities: A Position Statement of the American Diabetes Association, dated February 2016, the article indicated, No concentrated sweets or no sugar diet orders are ineffective for glycemic [A measure of the increase in the level of blood glucose (a type of sugar) caused by eating a specific carbohydrate (food that contains sugar) compared with eating a standard amount of glucose] management and should not be recommended. Instead, a consistent carbohydrate meal plan that allows for a wide variety of food choices (e.g., general diet) may be more beneficial for both nutritional needs and glycemic control in patients with type 1 diabetes or type 2 diabetes .
During a review of the facility's policy and procedure (P&P) titled, Resident Meal Service, dated 1/25, the P&P indicated, Policies: Residents will be offered menu choices for all meals, beverages and snacks and are based on their prescribed diet, food preferences.and consistent with their plan of care.
During a review of the facility's policy and procedure (P&P) titled, Resident Menu Planning, Approval and Revision, dated 1/24, the P&P indicated, Policies: Menus are written to meet the nutritional needs of the resident population in accordance with established national guidelines.Dietitian approves the menu nutritional adequacy with established national guidelines and refers to menu guidelines.
During a review of NCM, dated 2025, NCM indicated RDs had a role in menu planning and diet manual implementation,.The NCM Diet Manual is the guide for menu planning.Review Obsolete Diets to ensure you avoid using these diet terms in your facility ' s accepted diet terminology.
Diet names used in all areas should match: medical record documentation (electronic or paper), printed menus or tray tickets, diet manual, documents used by the kitchen staff (i.e. menu spreadsheets), diet guide sheets, and policies and procedures.