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If the residents complain to a surveyor or if a surveyor finds that your facility has issues with weight loss, then they may investigate further.You also want to be sure that you have a written policy to explain what you are doing if your meal times do not meet the 14 hour rule - and what you are providing as the “nourishing HS snack” to be sure you are complying with the regulation.The CMS State Operations Manual Appendix PP - Guidance to Surveyors for Long Term Care Facilities can be found here: Laws And Regulations/12_(See F363 Menus and Nutritonal Adequacy).I have been asked to go into a long term care facility to help them prepare for the state survey.Our Policy and Procedure Manual has a specific “Meal Times and Frequency” policy and procedure that covers this (2013 edition – page 2-29).We use the explanation that a “substantial evening meal” is defined as offering of 3 or more menu items at one time, one of which includes a high quality protein…The meal should represent no less than 20% of the day’s total nutritional requirement.Born out of the nightmare that was our story, our foundation rests on the single question.

Adequacy of the snack will be determined both by individuals in the group and evaluating the overall nutritional status of those in the facility.

The State Operations Manual Appendix PP - Guidance to Surveyors for Long Term Care Facilities will help with the federal regulations and will give you the F Tags for federal guidelines as well as the Investigative protocols for the survey process. Does the POC give a clear picture of the current nutritional status and is it changed often to reflect current status, goals, needs? Have the dietitians followed best practice guidelines for the clinical documentation? This week the administrator told me a surveyor was in to review a non-food service issue.

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