Provision of Dietary Services from Hospital
Off-site Location
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of BQA 99-047 (PDF, 11 KB) - includes attachment
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Date: August 18, 1999 DSL-BQA 99-047
To: Hospitals HOSP 17
From: Susan Schroeder, Director, Bureau of Quality Assurance
The purpose of this memorandum is
to provide you with information we received [see below] from the federal Health Care Financing
Administration. This information clarifies the provision of dietary services from off-site
locations. Though dietary services may be provided by a contracted service, the hospital
is responsible for meeting the food and dietetic services condition of participation at 42
CFR 482.28 and the dietary services regulations in Wisconsin Administrative Code, Chapter HFS 124
(exit DHFS) Hospitals Rules.
Please share this information with appropriate staff. If you have questions, please
contact Jean Kollasch, Dietary Services Consultant, Bureau of Quality Assurance, at (608)
267-0466.
DATE: [Undated memo received electronically in the RO on 7-14-99.]
FROM: Director, Clinical Standards Group, Office of Clinical Standards and Quality
SUBJECT: Provision of Dietary Services from Off-site Locations
TO: Associate Regional Administrators
Division of Medicaid and State Operations
Regions I-X
We recently learned of some inconsistencies in applying the hospital condition of
participation (CoP)--Food and Dietetic services when dietary services are provided from
off-site locations. The purpose of this memorandum is to provide guidance regarding
interpretation of 42 CFR 482.28, food and dietetic services for hospitals.
The food and dietetic services CoP at 42 CFR 482.28 states:
The hospital must have organized dietary services that are directed and staffed by
adequate qualified personnel. However, a hospital that has a contract with an outside food
management company may be found to meet this condition of participation if the company has
a dietitian who serves the hospital on a full-time, part-time, or consultant basis, and if
the company maintains at least the minimum standards specified in this section and
provides for constant liaison with the hospital medical staff for recommendations on
dietetic policies affecting patient treatment.
There are several ways by which hospitals may provide dietary services: 1) hospitals
may provide the service in the traditional configuration where the kitchen is located on
the hospital premise; 2) hospitals may provide the service directly, but may prepare the
bulk of the meals in a kitchen owned by the hospital, located off-site; and 3) hospitals
may contract out for dietary services through an off-site vendor. The hospital dietary
services CoP does not specifically require a hospital to have dietary services/food
preparation on the hospital premise. When foods are prepared off-site, modern technology
makes it possible to transport foods without compromising quality. If the hospital
provides dietary services through an off-site vendor, the vendor is under contract with
the hospital. In such instances, the standard for contracted services (42 CFR 482.12(f)),
under the Governing Body CoP, is applicable. However, regardless of how the hospital
provides the service, the hospital is ultimately responsible for meeting the dietary
services CoP.
To determine compliance when dietary services are provided from an off-site location,
surveyors can monitor compliance by reviewing such things as:
-
integration into the quality assurance program,
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integration into the infection control program,
-
integration into the dietetic policies and procedures in regards to meal service for off
hours’ admissions, late trays, food substitutions, reasonable meal schedules, posting
of current menus in the hospital as well as in the off-site kitchen, tray accuracy, food
handling safety practices, emergency food supplies and deliveries, staffing and patient
satisfaction,
-
a current therapeutic diet manual approved by the dietitian and medical staff,
-
nutritional assessment indicating nutritional needs are met in accordance with
recognized dietary practices as well as with orders of the practitioners responsible for
the care of the patients.
/s/ Mary R.Vienna
cc: Joan Simmons, CMSO
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