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Guidance for F371

PDF Version of DQA 11-033  (PDF, 80 KB)

Date: December 5, 2011 -- DQA Memo 11-033
To: Nursing Homes NH 23
From: Juan Flores, Director
Bureau of Nursing Home Resident Care
Via:

Otis Woods, Administrator
Division of Quality Assurance

Guidance for F371

This memo is to provide guidance for F371, Sanitary Conditions. According to the Centers for Medicare and Medicaid Services (CMS) State Operations Manual (SOM) at F371, there are specific requirements facilities need to follow to ensure individuals residing in long term care nursing facilities are protected from foodborne illnesses and that food is not purchased from unapproved sources.

Background

The regulatory language for Sanitary Conditions at Tag F371, located in Appendix PP of the SOM states the facility must:

483.35(i) (1) Procure food from sources approved or considered satisfactory by Federal, State or local authorities; and

483.35(i) (2) Store, prepare, distribute and serve food under sanitary conditions.

In standard long term care surveys, the citation frequency for F371 in FY 2010 (October 1, 2009- September 30, 2010) was as follows:

Nationally: ranked 3rd out of the top 10 most frequently cited deficiencies
Regionally: ranked 3rd out of the top 10 most frequently cited deficiencies
Wisconsin: ranked 2nd out of the top 10 most frequently cited deficiencies, representing 32.2 % (127 citations) of long term care providers

Examples of F371 deficient practices in Wisconsin include:

  • Sanitizer in dish machine not working and no system in place for monitoring;
  • Handwashing not in accordance with accepted standards of practice; staff repeatedly re-contaminating hands;
  • Cabinet handles soiled with dried food debris and build-up of a brown substance;
  • Casserole brought in by a resident's family was not reheated to the appropriate temperature;
  • Staff not following manufacturer's directions for proper concentration of the sanitizer solution for kitchen equipment (Ex. 3-compartment sink sanitizing and sanitizer buckets);
  • No hair restraint on or hair restraints not effectively covering hair, including facial hair;
  • Undated/unlabeled food items;
  • Bare hand contact with ready-to-eat food;
  • Thermometer not sanitized between individual food items;
  • Dietary aide touched his glasses, moustache and face with his gloved hands, then served twice baked potatoes with the same gloved hands;
  • Improper cooling of food items; and
  • Single-use disposable gloves being worn for multiple tasks.

The Centers for Disease Control and Protection (CDC) estimates that each year roughly 1 in 6 Americans (or 48 million people) gets sick, 128,000 are hospitalized and 3,000 die of foodborne illness. Residents in nursing homes are identified as a "highly susceptible" population because they are more vulnerable to developing a foodborne illness and complications such as a lengthier illness, being hospitalized, or even death.

The Food and Drug Administration (FDA) Food Code, is the main reference/current standard of practice for safe food operation and is the resource that was used for the development of the surveyor guidance for F371. The current Food Code is the 2009 edition with a recent release of supplement/updates.

In the Food Code, five major risk factors for foodborne illness are identified:

  1. Improper holding temperatures
  2. Inadequate cooking, such as undercooking raw shell eggs
  3. Contaminated equipment
  4. Food from unsafe sources
  5. Poor personal hygiene

In FY 2010, surveyors found numerous deficient practices related to all of the above risk factors except food from unsafe sources.

Resources

The following resources are available to assist facilities in achieving compliance for F371.

Every facility should have available and effectively use the information through the 2009 FDA Food Code and 2009 FDA Food Code supplement. Check your policies, procedures and staff training to determine if they reflect the most current standards for safe food handling.

2009 FDA Food Code

2009 FDA Food Code Supplement

The Division of Quality Assurance (DQA) and the Division of Public Health (DPH) developed a webcast, "Sanitary Conditions-Surveyor Guidance Training, 483.35(i) F371

Centers for Medicare and Medicaid Services, State Operations Manual, Appendix PP

Additional Suggestions

Memberships/subscriptions in professional organizations that keep individuals up-to-date on issues related to food safety:

Academy of Nutrition and Dietetics (formerly American Dietetic Association) 

Subgroups: 

Dietetics in Healthcare Communities
Management in Food and Nutrition Systems

Association of Nutrition & Foodservice Professionals (formerly Dietary Managers Association)

Self survey using the QIS Kitchen/Foodservice Observation form. Wisconsin is not yet a QIS state, but the form is very comprehensive and follows what surveyors will be observing.

USDA Food Safety and Inspection Service

Available trainings for food safety:

Certified Food Protection Professional

ServSafe Food Handler Training

Vendors that supply products for the kitchen may also provide food safety training to their customers.

Questions

If you have questions about this information, please contact Vickie Bergquist, Dietitian Consultant, Division of Quality Assurance at (920) 983-3184.

References

"CDC Estimates of Foodborne Illness in the United States"

Centers for Medicare and Medicaid Services, State Operations Manual, Appendix PP

"Estimates of Foodborne Illness in the United States"

Food and Drug Administration (FDA) Food Code (2009)

ServSafe Course book, (5th ed.) National Restaurant Association

 

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Last Updated: August 07, 2013