Page 52 - The Deep Seated Issue of Choice

THE DEEP SEATED ISSUE OF CHOICE
WHAT MAKES NEW IDEAS DIFFICULT?
The ongoing controversy in the field over food temperature at point of service illustrates the variability of interpretation. In the fall of 2008, a Health Quality Review Specialist for CMS provided a widely distributed professional opinion stating, in part: “The minute food leaves the tray line, the temperature will drop. Hence, the food that the resident receives will probably not be at 135 degrees unless it is something that will hold the temperatures (soup, mashed potatoes, etc). Once the resident receives the tray, it becomes a palatability issue.” Yet in January 2010, facilities are continuing to receive citations for point of service temperature for foods below 135 degrees when served to residents on trays from a centralized kitchen. And while it would seem logical that the same reasoning would apply for cold foods, related citations are being written today regarding cold food temperatures.
Variability abounds, surveyor-to-surveyor and state-to-state, placing the provider in the difficult position of attempting to clarify during survey, or in the IDR process. With the sophistication of modern technology, a “real-time help-desk or information base” available to providers and surveyors alike could help eliminate the confusion with the immediate availability of common information.
Variability could be further decreased through centralization of training and consultation at the federal level to decrease state variability in interpretation of federal standards. A strong, centralized, national technical consultation and training section to field questions from providers and surveyors, to disseminate relevant information to all stakeholders and to produce educational and best practice training materials for use by facilities in implementing best practices would greatly reduce the opportunity for varying state interpretations to be inserted into the intent of the federal regulation. State training efforts could be transferred to support consultation and collaboration in state coalition efforts, to support providers in implementation of resident- directed care, and to work at reducing the variability in state regulations. Providers could then focus on the delivery of quality care rather than independently researching practice standards or individually and independently developing training materials.
The variability between state and federal standards, and the lack of consistency in support of resident rights and self-determination, leads to confusion and inequalities from state to state. This variability must be addressed through a coordinated effort between states and CMS, and could perhaps be a national program for focus through either state coalitions or a national program of state advisory groups, formed to assure representation of all stake holders at the table when regulations are reviewed and revised. National adoption of appropriate programs such as dining (feeding) assistant and medication administration aides should be a priority focus to assist in the provision of quality dining and quality care.
As for the now infamous “food from approved sources” guideline, there appears to be agreement nationally that, with proper education of residents, families and staff, residents have a right
to choose to eat foods from unapproved sources. But that is the end of the common ground. Some states require education on food safety for residents and staff; hundreds of training programs are being developed by individual facilities, but one training program, developed by federal experts and available to all providers through the wonders of downloading, could likely
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