Lack of Registered Dietician Oversight in Nutritional Assessments
Penalty
Summary
The facility failed to ensure that the Dietary Technician (DT) received appropriate oversight and supervision from the Registered Dietician (RD) in the assessment and ongoing nutritional care of two residents. According to the 2024 Scope and Standards of Practice for Nutrition and Dietetics Technician, Registered, NDTRs must work under the clinical supervision of an RDN when engaged in direct patient nutrition activities, and the RDN is responsible for completing nutritional assessments and supervising technical staff. However, documentation for both residents showed that the DT completed nutritional assessments and progress notes without evidence of RD review or consultation, even in high-risk cases. One resident was admitted with multiple pressure ulcers and diabetes, and experienced significant weight loss over a 90-day period. The DT documented all aspects of the nutritional assessment and progress notes, including diet orders, weight trends, and interventions, but there was no indication that the RD had reviewed or participated in these assessments. The DT also signed progress notes as the dietician, and during interviews, described managing the resident’s nutritional care independently, including offering supplements and adjusting menus based on preferences and intake, without documented RD involvement. Another resident was admitted after a recent stroke with difficulty swallowing and experienced a notable weight loss within one week of admission. The DT again completed the nutritional assessment and implemented interventions such as fortified foods and weekly weights, but there was no documentation of RD oversight or consultation. Interviews with the RD revealed that she relied on the DT to alert her to high-risk cases and did not routinely review or sign off on assessments or attend relevant meetings. The RD was unaware of the specific high-risk cases and the DT’s practice of signing notes as the dietician.