CMS Adds Additional Pathway for Food and Nutrition Services Directors

CMS; Regulations

As the October deadline draws closer for compliance with the food and nutrition director requirements, a reminder that the Centers for Medicare and Medicaid Services (CMS) added to the requirements for the director of food and nutrition services at § 483.60(a)(2)(E) as part of the 2023 SNF PPS rule published in August 2022. These additions to the regulation allow for another pathway for the director of food and nutrition to qualify for the position; this includes having two or more years of experience in the position of director of food and nutrition services in a nursing facility setting and has completed a course of study in food safety and management, by no later than October 1, 2023. Course topics integral to managing dietary operations include, but are not limited to, foodborne illness, sanitation procedures, and food purchasing/receiving. 
CMS has note​​d that the course requirements would be the equivalent of a ServSafe Food Manager certification. Providers need to enroll in and complete the required training before October 1, 2023, in order to qualify for the role. 
Key points providers should consider in relation to meeting the requirements for the Director of food and nutrition: 

  • ​An assistant director, supervisor, or manager of food & nutrition services or other related titles/roles can qualify as having “2 or more years of experience in the position of director” if the individual’s defined role and the duties they performed in that role comply with the requirements. Titles, such as director, supervisor, or manager, are often used interchangeably and can vary.  

  • The requirement to have two or more years of experience in the position noted can have occurred at any point before the final rule effective date of October 1, 2022, to meet the qualification requirements.  

  • ​​Facilities that would qualify as a “nursing facility setting” for the purposes of this federal requirement can vary as long as the experience supports the individual’s ability to serve in the position in the long-term care setting.