​Dining sanitation and food safety, regulated by food and nutrition tags, including the F-812 tag, consistently rank among the top citations during state surveys of nursing homes.

So far in 2024, the issue has topped the list, with approximately 44 percent of skilled nursing facilities (SNFs) being tagged, according to Proactive LTC Consulting. F-812 requires that facilities follow professional standards for food service safety regarding storage, preparation, distribution, and serving of food.

These violations are difficult because fines can become hefty in a hurry. Each violation tag is graded from A to L. “A” through “E” doesn’t come with a fine. But starting with “F,” fines range from $130 to $7800 per day and from $2,500 to $25,000 per instance, depending on the violation. An outbreak of a foodborne illness would be an example of a costly violation.

Citations are judged based on their scope and severity. They could be isolated instances, ones that happen in a few places, or widespread ones. For example, if a bad batch of hamburger meat is used, it would be widespread.

Though most nursing homes have internal compliance measures—such as basic certifications, food handling policies, and on-the-job training—surveyors often catch even the best-intentioned teams in violations.

Post Guidelines for Easy Reference

Long term care facilities can get ahead of survey citations with a dining audit. Tracy Malloy, a registered and licensed dietitian with 30 years of long term care experience, conducts four to six audits each month as a compliance manager for the Friends Services Alliance (FSA) Compliance Collaborative in Blue Bell, Pa.

“It’s not that the employees don’t care—they care very much,” Malloy said. “But there’s a turnover rate of employees and supervisors. This disrupts the consistent training and oversight necessary to maintain compliance.” Although nurse staffing shortages in our industry may be improving, dining staffing shortages are not. These are tough jobs to fill, she said.

Malloy said improper temperature tracking and dishwashing sanitation failures frequently trip up nursing home teams. Violations show up in temperature logs when there are missing entries or dishwashing machine issues, such as water temperature and overall general sanitation.

For example, fixed equipment must be properly cleaned. The removable parts must be washed and sanitized, and non-removable parts must be cleaned with detergent and hot water, rinsed, air-dried, and sprayed with a sanitizing solution. Staff can find information about storage and cleaning on the appliances’ doors. Laminated signs posted throughout the kitchens point out the guidelines for easy reference.

Malloy emphasized the importance of kitchen personnel being ServSave-certified. She said at least one kitchen member should be certified and encouraged the entire team to take the course.

ServSafe is a certification program by the National Restaurant Association, and the ServSafe Food Handler program typically takes 1.5 to 2 hours to complete. The ServSafe Manager course is significantly longer, taking approximately eight hours to finish the online modules and study materials.

Annual and ‘Surprise’ Audits

The FSA Compliance Collaborative conducts dining audits at the request of skilled nursing facilities to help them proactively prepare for state and county inspections. The state’s survey office performs its audits annually, with some wiggle room. However, the annual audit must be completed within three months of the last time it was conducted.

In most states, the local county also conducts an inspection. Malloy said the county shows up at the facility without warning in those cases.

“These audits are well-intentioned; they are designed to make the kitchens better than they are,” Malloy said. 

The walk-through time for an FSA audit takes one to three hours, depending on the size of the kitchen. The audit comes with a report that outlines the findings and suggestions.

“I’m a big proponent of education,” Malloy said. Educational information is available from the Academy of Nutrition and Dietetics and the National Restaurant Association. Many resources are also available online.

Malloy noted that a new set of eyes can help detect things that are easily overseen, such as daily grease build-up on the kitchen hood.

“It happens gradually, and before you know it, a heavy accumulation must be removed,” she said. “You walk by it every day and don’t notice it, or there’s the dirt that might be in nooks and crannies on the wall.”

She said that sometimes the employees are in a rush. The kitchens of long-term care facilities are full of constant activity. Shifts begin at 5 a.m. and end at 8 p.m.

“The staff has to prep, prepare, and serve the food to 80 different residents, for example,” she said. “That’s a lot of food preferences, likes and dislikes, different diets, and different textures. It’s a hard balancing act.”

Audits Can be a ‘Pre-emptive Strike’

Darrell Grimmett, senior director of dining services at Life Enriching Communities, said audits identify the critical goals his kitchens want to achieve.

“They are a pre-emptive strike that shows us what to focus on,” he said. “This helps us to score consistently in the 93rd to 95th percentile for cleanliness.” Grimmett supervises a six-community portfolio in Ohio. Each property employs about 35 to 40 kitchen workers to serve about 130 to 150 residents.

“The audit points out items at risk or not in compliance,” he said. “The auditor checks labels and dates and advises on how to better store our products on our shelves and create more efficient processes,” said Grimmett. “It also assists us with meal service opportunities and ensures that our documentation and record-keeping are compliant.”

Grimmett, who grew up in the restaurant business, said compliance is always an ongoing issue.

“It’s a constant battle; you can’t relax on anything,” said Grimmett, who has the Level 2 SafeServ certification designed for supervisors. Holding the certification is mandatory for his company’s employees.

For nursing home residents, food is about more than just nutrition—it’s central to their socialization, memories, and overall quality of life. Violations of the F-812 tag can have severe consequences, not just in financial penalties but also reputational damage.

Paul Bergeron is a freelance writer based in Herndon, VA.