Inadequate Nutritional Oversight Due to Staffing Deficiencies
Penalty
Summary
The facility failed to employ sufficient staff with the necessary competencies and skills to ensure appropriate nutritional oversight for residents. The full-time Director of Food and Nutrition Services (FSD) was not a qualified dietitian or clinically qualified nutrition professional and did not receive frequent consultations from a qualified dietitian. The facility's assessment did not indicate the necessity of a qualified dietitian to meet the nutritional needs of the residents, which is a requirement under federal regulations. The FSD, who is a Certified Dietary Manager, confirmed that she does not meet the minimum qualifications to be a qualified dietitian. Although the facility employs a part-time registered dietitian (RD) who works remotely, the FSD's interactions with the RD were limited to email and telephone communications. The FSD attended care plan meetings and documented residents' food preferences, but her scope of practice did not include clinical assessment and evaluation for medically related nutritional therapy. The part-time RD confirmed that she completes all job tasks remotely and does not conduct on-site consultations or oversight. She relies on input from the interdisciplinary team, including the FSD, to complete nutritional assessments. The RD has not been in the facility to observe residents' eating abilities or provide direct nutritional consultation, which limits her ability to fulfill her responsibilities effectively. The nursing home administrator could not provide documentation confirming the RD's on-site consultation or oversight role.
Plan Of Correction
1. A RD was hired to provide 10 hours/week of onsite dietary support and evaluation. 2. The facility will maintain an onsite RD. 3. The recruiter was re-educated on ensuring that an onsite RD was available to the facility for at least 10 hours/week. The NHA will report open positions to the recruitment department. 4. The NHA or designee will conduct an audit of RD onsite hours weekly x 4 weeks then monthly x 2 months to ensure onsite support is provided. The results will be submitted to the QAPI Committee for review and analysis of need for ongoing monitoring.