October 1, 2023, Deadline for Food and Nutrition Director Requirements

IIn August 2022, the Centers for Medicare and Medicaid Services (CMS) introduced new regulatory language concerning food and nutrition services  as part of the Fiscal Year 2023 Skilled Nursing Facility (SNF) Prospective Payment System Final Rule (CMS 1765-F).
These revisions provide an alternative avenue for individuals seeking to qualify as directors of food and nutrition, this alternative entails:
  • Having two or more years of experience in the position of Director of Food and Nutrition Services in a nursing facility setting; AND
  • Completing a course of study in food safety and management, by no later than October 1, 2023. Course topics integral to managing dietary operations include, but are not limited to, foodborne illness, sanitation procedures, and food purchasing/receiving.
Crucial aspects for members to consider with regard to fulfilling the requirements for the Director of Food and Nutrition include:
  • An assistant director, supervisor, or manager of Food and Nutrition Services or other related titles/roles can qualify as having “two or more years of experience in the position of director” if the individual's defined role and the duties they performed in that role comply with the requirements. Titles, such as director, supervisor, or manager, are often used interchangeably and can vary.
  • The requirement to have two or more years of experience in the position noted can have occurred at any point before the final rule effective date of October 1, 2022, to meet the qualification requirements. 
  • Facilities that would qualify as a “nursing facility setting” for the purposes of this federal requirement can vary as long as the experience supports the individual's ability to serve in the position in the long-term care setting.
CMS has determined the educational requisites for this program align with the standards set by a ServSafe Food Manager certification. To be eligible for the role, providers must enroll in and satisfactorily finish the mandatory training before October 1, 2023.
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