This manual is a companion to and expands the topic started in the author's manual entitled Dietary Services: Mastering Survey and Mastering QAPI. Leadership (Dietitians and Dietary Managers) in healthcare kitchens (hospital and LTC/Nursing Homes) can no longer "assume" that since they have had "OK" surveys in the past, that these will be acceptable in the future. The new emphasis of CMS is for staff (leadership down to the front line cook or dishwasher staff) to learn to be proactive and forwarding thinking. How this is different from the old, retrospective reaction of responding to surveyor- found deficiencies without the ability to defend yourself and your systems? It puts the burden squarely upon your shoulders in leadership. Set up systems that SHOW a surveyor how every detail in your strong system has a goal of food safety. Will there be an occasional staff error? Of course, but you can demonstrate that your system will correct this. It is a paradigm shift, to train staff on HOW to identify potential unsafe food handling (Root Cause Analysis) and prevent an "Adverse Event", in this case "Food Borne Illness." This manual provides practical guidance to help you evaluate:

1. Regulations: Are you prepared to demonstrate HOW your staff & your systems meet the intent of regulations (A tags for Hospitals/F tags for Nursing Homes), being able to respond to surveyor evaluations in the new CMS (hospital patient safety) surveyor worksheets for Infection Control Preventing Food Borne Illness) and QAPI? Nursing home dietary leadership can learn a tremendous amount from these.

2. Policies and Procedures: Are they based upon "national standards" of food safety, which includes the current Food Code (2013), manufacturer's guidelines, even the new Safety Data Sheets? Are all these practices defined so there is no doubt what is expected of staff? If you are a small facility with limited resources, how can you customize a commercial P & P? (Or do you wait for a surveyor to read the details of your chemical label, manufacturer label, or test strip procedure and "grill" your staff regarding their lack of knowledge or improper procedures?)

3. Food Safety Training: Is it extensive from initial orientation to ongoing reinforcement? Can you demonstrate that your training methods are effective to ensure competency for ALL staff in all job duties? (Or do you use old "once a month" training without trying more effective adult learning methods like weekly focus huddles and posted reference "Visuals" for weak areas and reinforcement?)

4. Monitoring: Is it thorough? To determine weak areas for additional training & performance improvement projects? This is as important & challenging to a large kitchen with many managers to a small kitchen with one full time manager and a part time consultant dietitian. (Or do you wait for the surveyors to identify these training needs? Or wait for an Immediate Jeopardy, IJ? Manual will review IJs on mold, pests, eggs, etc.)

5. Performance Improvement Projects (PIPs): Can you show that you have many PIPs where you are benchmarking improvement? (Or do you wait for the deficiency write ups from surveyors so your "Plan of Correction" can then be in a perfect PIP format?)

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