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2740 GRANT STREET

CONCORD, CA 94524

LICENSURE OF PERSONNEL

Tag No.: A0023

Based on dietary management staff interview and departmental document review the hospital failed to ensure the position responsible for day to day operations and supervision of dietetic services met applicable state certification requirements. Failure to ensure staff qualifications may result in dietetic services practices that put patients at nutritional risk.


Findings:


1. California Code of Regulations, Title 22; Division 5, Chapter 1, Article 3 specifies Dietetic Services Staff qualifications. The regulatory requirements specify that if a Registered Dietitian (RD) is not employed full time, a full time person who has completed a dietetic supervisor ' s training program shall be employed to be responsible for the operation of the food service.


In an interview on 3/25/16 beginning at 1 p.m., with RD 1 she stated her responsibilities were limited to the clinical nutrition care. Dietary Management Staff (DMS) 2 was responsible for the daily management of foodservice operations. In an interview on 3/26/16 beginning at 10 a.m. with DMS 2 he stated that he has been an employee of the health system for many years, working his way into the management position. He further stated that while he started the educational requirements required to become certified, has not completed the program.


Review of hospital position description titled " Nutrition Services Manager-Behavioral Health Center " dated 1/16 failed to fully reflect the regulatory qualifications for dietetic services staffing; rather noted that the required educational/certifications were a preference rather than a requirement.


Review of hospital document titled " Nutrition/Food Service Agreement " dated 4/14/16 revealed that " The Management of ...shall be responsible along with Behavioral Health ...and ....Administration to recruit and select a qualified Nutrition Services Operations Manager to assume day to day managerial responsibilities ... "


2. California Code of Regulations, Title 22; Division 5, Chapter 1, Article 3 specifies Dietetic Services Staffing. The regulatory requirements for dietetic services specify that a registered dietitian shall be utilized to provide advice to the administrator, patient counseling and guidance to the supervisor and staff of dietetic services.


In an interview on 5/23/16 beginning at 1 p.m., RD 1 stated she was employed by a separately licensed hospital and her primary responsibility was providing clinical nutrition care to the behavioral health hospital, three days per week. Her remaining time was spent at a separately licensed hospital. Her daily duties focused on nutrition assessment of patients who were identified at nutritional risk. She described that DMS 2 was the person responsible for foodservice operations and while she occasionally helped with education and an annual food distribution evaluation she did not provide any dietetic services oversight. Review of hospital document titled " Nutrition/Food Service Agreement " dated 4/14/16 failed to note the services of a Registered Dietitian. Review of hospital document dated 11/15, titled Dietitian Clinical " described the duties of this position as providing nutrition assessments, patient counseling, development of policies and procedures as well as the liaison for clinical nutrition care with medical staff, nursing and administration

PATIENT RIGHTS: INFORMED DECISION

Tag No.: A0132

Based on interview and record review, the hospital failed to follow their policy and procedure ( P&P) for Advance Directives (AD: a written plan for medical care when a patient is unable to speak for themselves) for two (Patients 5 ,and 6) of 34 sampled patients. This failure had the potential to deny patients the right to participate in their medical healthcare decisions.

Findings:

The P&P dated 4/16, titled "AD-Advanced Directive/Psychiatric Advance Directive, indicated the following:

Purpose:
To provide a consistent method for communicating and documentint the patient's response re: Advance Directives. To provide written information at the time of admission to all adult and emancipated minor in-patients about their rights to make decisions regarding their medical care

Procedure:

1. Each inpatient, upon admission to the hospital will be asked whether they have an advance directive or would like information about one by the admitting nurse. All patients patients about the age or 18 and emancipated minor, shall be advised of their right to formulate an Advance Directive. The staff person discussing this information shall sign the appropriated section of the Condition of Admission and Advance Directive From so as to document whether the individual has executed an Advance Directive.

2. If the patient has made a determination toward an Advance Directive, a copy of the document must be obtained and placed in the patient's chart, to be filed under the designated tab.

Medical records review on 5/24/16 indicated the following:

For both patients Patient 5 and Patient 6: The Conditions of Admission/Registration dated 5/22/16 failed to have a Health Care Directive Documents which noted the patient's choice for health care directives.

On 5/24/16 at 11 AM, registered nurse (RN) 7 stated the Health Care Advance Directive section should have been completed by the admitting nurse at the time of the patient's admission.

DATA COLLECTION & ANALYSIS

Tag No.: A0273

Based on administrative staff interview and dietary document review the hospital failed to ensure an effective performance improvement program for food and nutrition services that accurately reflected the depth and scope of departmental operations. Failure to develop a comprehensive program that identifies opportunities for improvement may result in compromised outcomes, for a patient census of 40, in relationship to medical and nutritional status.


Findings:


During meal distribution observation on 5/23/16 beginning at 11:45 a.m., Dietary Staff (DS) 4 was observed plating meal trays. In an interview on 5/23/16 at 2:30 p.m., she described food portions were determined through the use of production sheets. Concurrent review of the production sheet for the noon meal revealed that for each food item there was an associated portion. As an example the roast beef portion was designated to be 4 ounces. Food production observations on 5/24 and 5/25/16 in the adolescent unit and the hospitals ' café failed to note neither use of production sheets nor a mechanism to ensure physician ordered therapeutic diets were followed (Cross Reference A630).


In an interview on 5/25/16 beginning at 11 a.m., with Contract Staff 4 she presented dietary departments ' performance improvement activities. The 2015 topics included the use of a " multidisciplinary team approach to develop a select 7 day carbohydrate counting diabetic menu. " While the hospital identified the need to develop and implement the menu in January 2016 there was no evaluation whether or not the menu implementation was in accordance with hospital approved dietary parameters or physician ordered diets (Cross Reference A630).

SELF-ADMINISTRATION - DRUGS FROM HOME

Tag No.: A0413

Based on observation, interview, and record review, the hospital failed to ensure it developed and implemented a policy and procedure for nurse practitioners to identify patient own medications (prescriptions filled at an outside pharmacy that a patient brings to Off-Site 1). In Off-Site 1, nurse practitioners filled medication cassettes with patient's own medications. This failure resulted in the potential for patients to be exposed to preventable medication errors.

Findings:

During a concurrent tour and interview, on 5/23/16 at 1:50 pm, in the entry to the Off-Site 1, Lead Treatment Associate (Treatment 1) was asked to describe how the staff handled patient medications. Treatment 1's description included the hospital's nurse practitioners used the patient's own medication to fill a medication cassette (tray with compartments to store medications for administration). She described the filled medication cassette was secured in a patient locker. Her description included that a patient would self-administer their medications using the medication cassette. The lockers were identified to the right side of the reception desk.

During a group interview, on 5/24/16 at 2:20 pm, the hospital's nurses were asked to describe how medication cassettes were filled at Off-SIte 1. The group included Registered Nurse 5, Nurse Practitioner 1, Nurse Practitioner 2, and Pharmacist-in-Charge. The group's description included that they compared the description on the prescription label with the contents of the prescription.

An administrative record review, of the hospital's policy and procedure for MM-CFR Residential Medication Management (Revision Dates: 4/15) showed, III Procedure;, C. Medication Verification, 1. "For patients who are classified as a Level 1 (needs assistance with medications), all medications that are brought from home will be reviewed by the pharmacist, or Nurse Practitioner for verification..." Continued review did not show a procedure for nurse practitioners to verify patient own medications.

An administrative record review, of the hospital's Nurse Practitioner-Psychiatric (Rev: 4/16) showed, Position Summary:, "The Nurse Practitioner (NP) is responsible for providing psychiatric evaluation and treatment of the hospital for Recovery inpatients and outpatients in collaboration with and under the direction of the Supervising Physician. The NP performs duties according to standardized procedures which have been developed collaboratively by hospital administration, medical staff, nursing, and Nurse Practitioners and approved by the Medical Executive Committee and the Governing Board." Continued review did not show drug identification and filling of medication cassettes were included in the job description.

PHARMACY ADMINISTRATION

Tag No.: A0491

Based on observation, interview, and record review, the hospital failed to develop and implement a policy and procedure to ensure self-administered inhalers were stored to prevent cross contamination (transfer of germs from inhaler to other medications) of other clean items. The hospital allowed patients to self-administer inhalers (device to deliver medication to the lungs). The inhalers were stored in the medication room, in the same plastic bin, with other patients' medications. This failure resulted in the potential for patients to be exposed to preventable infections.

Findings:

During a concurrent tour and interview, on 5/23/16 at 11:30 am, at the center for recovery nursing station, Pharmacist-in-Charge (PIC) identified the medication room. Inspection of the medication room showed a plastic bin labeled "internal". Inspection of the bin showed it contained patient specific (dispensed for one patient) bulk (contained more than one dose) medications. The medications included two inhalers. PIC stated the bin was used to store patient specific bulk medications. The hospital was requested to provide the policy and procedure for storage of medication on the nursing unit.

During a concurrent observation, interview, and record review, on 5/24/16 at 9 am, on the center for recovery nursing station, in the medication room, Licensed Vocation Nurse (LVN 1) identified Patient 16. Patient 16 was standing outside the room at the medication window. LVN 1 asked Patient 16 to describe his general health. Patient 16 stated that he was having diarrhea and had to go to the bathroom. LVN 1 stopped the medication administration process to allow Patient 16 to go to the bathroom. Patient 16 returned to the window and LVN 1 resumed the medication administration process. Medications administered to Patient 16 included loperamide (to treat diarrhea).

During a concurrent observation and interview, on 5/24/16 at 1:35 pm, in the center for recovery medication room, Registered Nurse (RN 2) identified the plastic bin labeled "internal". LVN 1 was asked to describe how inhaler medications were administered to patients. LVN 1's description included the patient holding the inhaler to self-administration the medication. LVN 1 acknowledged the inhaler was returned to the plastic bin for storage until the next medication administration time. LVN 1 acknowledged the facility practice of storing patient bulk medications in the bin with the inhalers. RN 2 was asked if the practice met the hospital's expectation for preventing cross contamination. RN 2 stated the described practice did not meet the hospital's expectation for preventing cross contamination from the inhalers.

An administrative record review, of the hospital's policy and procedure for MM-Medication Storage (Revision Dates: 1/15) showed, III. Procedure:, A. Various medication and security-related procedures shall be employed depending upon the location of the actual medication within the hospital., 2. Medications on the Units, a. "All medications on the Units are stored within the Pyxis Medstation (automated dispensing cabinet), with the exception of: patient's own medications, bulk medications (creams, inhalers, etc.), or occasionally non-Formulary medications in vials." Continued inspection did not show a process to ensure patient self-administered medications did not contaminate other items.

FOOD AND DIETETIC SERVICES

Tag No.: A0618

Based on foodservice observations, dietary staff interview and dietary document review the hospital failed to ensure the provision of effective food and nutrition services as evidenced by:

1. Food storage practices that did not reflect current standards of practice (Cross Reference A619);

2. Lack of development of departmental policies and procedures and lack of effective oversight of food production activities (Cross Reference A620);

3. Lack of menu development and nutritional analysis of diets commonly served to patients (Cross Reference A630);

4. Lack of development of a diet manual that reflected the scope of diets routinely ordered by hospital physicians (Cross Reference A631);

5. Lack of development of a comprehensive performance improvement program that reflected the depth and scope of food and nutrition services (Cross Reference A273).

ORGANIZATION

Tag No.: A0619

Based on dietary management staff interview and dietary document review the hospital failed to ensure the organization of dietetic services in a manner that ensured oversight of the hospitals' operations which included the Registered Dietitian, the position with the education and expertise to evaluate the hospitals' dietetic services. Failure to ensure comprehensive oversight may result in unsafe food handling practices and activities not in accordance with foodservice and hospital standards of practice. This had the potential to affect the hospital census of 40 patients.


Findings:


1. During an interview on 5/23/16 beginning at 9 a.m. with the Chief Nursing Officer (CNO) she stated that while the hospital had a nutrition services manager, the dietetic department was a contracted service integrated within the hospitals ' health system, specifically a separately licensed hospital on the same campus. The CNO stated there were 3 separately licensed hospitals within the health system all of which had separate administrative and medical staff with one shared governing body.


In an interview and concurrent organizational chart review on 5/24/16 beginning at 2 p.m., with Contract Staff (CS) 2, a health system employee, she stated Dietary Management Staff (DMS) 2 was an employee of the hospital, rather than the health system. She stated the hospital did not have an organizational chart that depicted only the Behavioral Health campus, rather to her knowledge the only approved organizational chart depicted the health system as a whole.


In an interview on 5/23/16 beginning at 1 p.m., with RD 1 she stated she was employed by a separately licensed hospital and her primary responsibility was to provide clinical nutrition care to the behavioral health hospital three days per week. She stated she was not responsible for oversight of foodservice operations. With the exception of an annual tray accuracy audit she did not review dietetic services operations. As a result of the hospitals integration with the health systems organizational structure the hospitals ' dietetic services did not meet State regulatory requirements (Cross Reference A23).

DIRECTOR OF DIETARY SERVICES

Tag No.: A0620

Based on food storage observations, dietary staff interview and dietary document review the hospital failed to ensure food storage in a same manner as evidenced by 1) storage of bread crumbs in refuse bags and 2) inaccurate dating of thawing meat. Failure to follow safe food handling guidelines may result in cross contamination and bacterial growth associated with foodborne illness. This had the potential to affect the hospital census of 40 patients.

Findings:

1. During initial tour on 5/23/16 beginning at 10 a.m., the following was observed:
a. In the dry storage there was a plastic container, lined with a clear plastic bag, containing bread crumbs. In a concurrent interview with DMS 2 he stated that the plastic liner was the same that was used for lining the trash cans. In a follow up interview on 5/24/16 at 9 a.m., with Contract Staff 3 she stated the vendor was contacted and it was confirmed that the bags were not rated for food storage. Review of hospital policy titled " Storage " dated 2/20/16 failed to provide any guidance for storage of bulk food items that were removed from the original packaging.


b. In the walk-in refrigerator there was 4 pieces of flank steak weighing 8 pounds each, 2 of which were fully thawed and 2 which remained partially frozen. All pieces were labeled as thawed on 5/22/16 with a use by date of 5/25/16. Similarly there were two 5-pound rolls of fully thawed ground beef labeled as thawed beginning on 5/25/16. There were also 4 bags weighing 8 pounds each of chicken, 2 of which were thawed and 2 of which were partially frozen all were labeled as pulled from the freezer on 5/12/16 with a use by date of 5/25/16, a total of 11 days.


In a concurrent interview with DMS 2 he was unable to explain how these large cuts of meat were fully thawed within 24 hours. Concurrent review of departmental invoice documents dated 5/12 and 5/17/16 revealed that all meat was received frozen. It was also noted that while the chicken was received on 5/12/16, hospital staff did not accurately label items during thawing. Based on safe handling guidance published by the United States Department of Agriculture, Food Safety and Inspection Service, (USDA-FSIS) 2016 " even small amounts of frozen food, such as a pound of ground meat or boneless chicken breasts, require a full day to thaw. " Similarly USDA-FSIS recommends " while foods are in the process of thawing in the refrigerator (40 Fahrenheit or less), they remain safe. After thawing, use ground meats, poultry and fish within 1 or 2 additional days, and use beef, pork, lamb or veal (roasts, steaks or chops) within 3 to 5 days. " Accurate thaw dates would be essential to ensure food safety guidelines are implemented.


It was also noted there was a laminated food storage chart that was posted in the walk-in refrigerator; however the guidance was not comprehensive, rather was limited to a few items such as salad dressing and unopened frozen foods. Review of the departmental policy and procedure manual dated 2015 failed to provide additional guidance. In follow up interview on 5/24/16 beginning at 10 a.m., with Contract Staff (CS) 4 she provided food storage charts that were obtained from the health system; however these documents were not incorporated into the departments ' ' policy and procedure manual and would not be readily accessible to staff.


2. Review of the department ' s policy and procedure manual dated 2015 revealed that while a department manual was established it did not fully reflect the scope and complexity of the department. As an example the procedure titled " Food Production, Service and Distribution Standards " dated 2/20/16 guided staff to thaw foods in the refrigerator; however provided no guidance on labeling, dating or holding time for thawing foods. Similarly this policy guided staff to refrigerate leftover foods promptly and to use within 24 hours; however there was no guidance on monitoring time/temperature control of heat treated foods. This policy was also inconsistent in that in the food production section it noted leftover food would be held for 24 hours whereas in the food labeling section it allowed for use within 3 days.

In an interview on 5/24/15 beginning at 10:30 a.m., with CS 3 she acknowledged that while there were additional procedural documents within the department, utilized by staff, they were not part of the hospitals ' approved policy and procedure manual.

DIETS

Tag No.: A0630

Based on meal distribution observations, dietary staff interview and dietary document review the hospital failed to ensure patient nutritional needs were met as evidenced by 1) lack of an effective system to ensure physician ordered therapeutic diets were followed for patients eating in the hospitals ' café area and 2) lack of development of a vegetarian menu. Failure to ensure effective systems for implementing physician ordered diets may further compromise the medical status of patients.


Findings:


1. During a concurrent observation and administrative record review, on 5/25/16 at 8:05, at the entrance to the café (patient cafeteria on the first floor), the posted mealtime schedule was identified. Inspection showed adult patients were served at 8 am, residential patients were served at 8:05 am, and CFR (center for recovery) inpatients were served at 8:15 am. The doors to the café opened at 8:06 am. Inspection of the café showed the food choices included: cold cereal, fruit, bread, coffee, yogurt, milk, butter, juice, scrambled eggs, scrambled eggs with cheese, tortillas, sausage, chorizo, potatoes, and oatmeal. Dietary Staff 5 served the hot food items. Patients took their food choices and sat down in the dining area. Several patients returned to the serving line for more food. During the observation the café staff did not restrict the patient ' s food choices and quantity. During the observation the café staff did not document the patient food choices and quantity.


During a concurrent interview and medical record review, on 5/25/16 at 9 am, Registered Nurse (RN) 4 identified Patient 25 ' s electronic medical record (EMR (computer medical record)). Inspection of the EMR showed insulin (medication to control blood sugar) was ordered on 5/21/16. Further inspection showed a regular diet was ordered on 5/20/16. Continued inspection showed physician notes on 5/21/16, 5/22, and 5/23. The three physician notes documented the daily (food) intake was not in the EMR. Further review showed Patient 25 ate 90-100% of his food when dining in the cafe. The hospital was requested to show documentation of the composition (calorie, carbohydrate, protein, fat) of Patient 25 ' s café meals.

During a concurrent interview and medical record review, on 5/25/16 at 10 am, RN 4 identified Patient 24 EMR. Inspection of the EMR showed insulin was ordered on 4/9/16. Further inspection showed a healthy diabetic (too much sugar in the blood) diet was ordered on admission. Further inspection showed Patient 24 ate 100% of her food when dining in the café. The hospital was requested to show documentation of the composition of Patient 24 ' s café meals.

During an interview on 5/25/16 at 10:45 am, Dietary Management Staff (DMS) 2, was asked to describe how the café served a physician ordered diet. The process included a nurse would order a special diet tray. The café staff would prepare the special tray in the kitchen. The special tray would be served to the patient in the café line. DMS stated the café did not serve the ordered diet unless the nurse requested a special tray.

During an interview, on 5/25/16 at 11:40 am, Director 1, was asked if the EMRs for Patient 25 and Patient 24 documented the composition of their café meals. Director 1 stated the EMR did not document the composition of Patient 25 and Patient 24 café meals.

2. During meal general meal distribution observation on 5/23/16 beginning at 11:45 a.m., Dietary Staff (DS) 4 was observed plating meal trays. In an interview on 5/23/16 at 2:30 p.m., she described that portions were determined through the use of production sheets. Concurrent review of the production sheet revealed that for each food item there was an associated portion. As an example the roast beef portion for the noon meal was designated to be 4 ounces.


During meal distribution observation and concurrent interview, on the adolescent unit, with Mental Health Staff (MHS) 4 on 5/24/16 beginning at 11:30 a.m., she stated that meal distribution consisted of checking the patients name band and date of birth, along with any pertinent food allergies. She also stated a list that depicted the physician ordered diet came with the meal cart. The meal distribution consisted of MHS 4 asking the patient what they wanted to eat and whether they wanted a large or small portion. In a follow up observation on 5/25/16 at 8:15 a.m., Registered Nurse 3 was observed plating the breakfast meal. It was noted that patients were asked which of the items they wanted to eat. There was no accompanying production sheet to determine food quantity with either of the adolescent meal plating observations.


In an interview on 5/25/16 with CS 4 she was asked to describe meal planning for patients with Diabetes. She stated that in January 2016 the hospital changed the method of providing meals to patients with diabetes. She stated that the current system is to monitor the carbohydrate intake of patients and adjust medications, in particular insulin, accordingly. She acknowledged there was no system in place to monitor the amount of carbohydrate for patients who did not receive pre plated meals. Hospital policies describing the nutrition management of Adult and Pediatric Diabetic Patients each approved on 2/24/16 described a procedure that limited the amount of carbohydrate selections per meal. The carbohydrate distribution was dependent on age and gender. The purpose of each of the procedures was to improve, normalize and optimize the control of blood glucose.


3. In an interview on 5/23/16 beginning at 11:05 a.m., with Dietary Staff (DS) 3 she was asked to describe the process for preparing patient meal tickets. She stated the hospital had three different systems, the first being meal plating in the kitchen, the second was the café buffet line and the third was meal plating within the adolescent unit. She described that patient meal tickets were prepared only for meal plating that occurred in the kitchen, the remaining meals were plated in the presence of the patient and in accordance with their preferences. In a concurrent observation DS 3 was preparing a meal ticked for a patient with a vegetarian diet. The selection for 5/23/16 was a vegetable stir fry. Meal plating observation on 5/23/16 revealed two random patients received the vegetarian meal which, consisted of a 6 ounce portion of sautéed cauliflower and red peppers, a 1/3 cup portion of steamed rice and a serving of butternut squash.


In an interview on 5/24/16 beginning at 10 a.m., with Contract Staff (CS) 4 she was asked to describe how the hospital ensured the nutritional needs were met of the patient population, which CS 4 stated were adults between the ages of 30-50. She stated that patients usually self-selected the menu. She confirmed that the hospital did not have a vegetarian menu, additionally while the hospital had a first choice menu (foods that would be plated if the patient was unable to select their food) there was no nutritional analysis of any of the hospital menus.


In a follow up interview on 5/25/15 beginning at 9:30 a.m. CS 4 presented a nutritional breakdown of the first choice, regular menu, which was completed on 5/24/16 (during the survey); however was not yet analyzed. Brief review of the menu analysis revealed that while it was nutritionally adequate in some vitamins, it was low in Vitamin D, Vitamin E, Vitamin K and Calcium. There was no comprehensive assessment of the hospitals ' menu in comparison to the nutritional needs of the hospitals ' population.

THERAPEUTIC DIET MANUAL

Tag No.: A0631

Based on contract and nursing staff interview and dietary department document review the hospital failed to develop and utilize a diet manual that was specific to the hospital; included diets routinely ordered; provided accurate guidance for ordering and preparing patient meals. This failure had the potential to result in a lack of consistency and communication concerning the diets among medical, nursing and dietary staff. This failure had the potential to affect the patient census of 40.


Findings:


Diet manuals establish a common language and practice for physicians and other healthcare professionals to use when providing nutrition care to patients. The diet manual includes the purpose and principles of each diet, the meal pattern, the foods allowed and foods to avoid and describes the nutritional adequacy and/or inadequacy of each diet. The diet manual and diets ordered by the hospital should mirror the nutritional care provided by the hospital.


In an observation on 5/23/16 beginning at 11:05 a.m., Dietary Staff (DS) 3 was preparing a meal ticket for a patient with a vegetarian diet. The selection for the day was a vegetable stir fry. Meal plating observation on 5/23/16 beginning at 11:30 a.m., revealed that the stir fry meal consisted of a 6 ounce portion of sautéed cauliflower and red peppers, a 1/3 cup portion of steamed rice and a serving of butternut squash.


On 5/24/26 beginning at 11:30 a.m., the hospitals diet manual was reviewed with Contract Staff (CS) 4 and Registered Nurse (RN) 2. The surveyor asked Registered Nurse 2 to demonstrate the diet manual. She stated that she was unaware of the existence of the manual. To her recollection this was not a component of her orientation training to the hospital. With the assistance of CS 4 a document titled " Nutrition Care Manual " was located on the hospitals intranet web site. RN 2 was asked to locate hospital specific guidance for the vegetarian diet. It was noted that while the nutrition care manual had information on a vegetarian meal plan, it did not have the elements of a diet manual; rather consisted of patient education materials reviewing the concepts of a vegetarian diet. There was no information specific to the hospitals vegetarian meal plan. In a concurrent interview CS 4 stated the hospital developed additional documents dated 10/15 titled " Diet Definitions, Adequacy and Supplements " for both the adult and pediatric diets to provide additional guidance. Review of the document revealed there was a column for the name of the diet, the definition and approved supplements for listed diets. The documents also revealed that while a vegetarian diet was listed it was limited to the purpose of the diet and nutritional supplements. There was no evaluation of the nutritional adequacy of the diet, review of foods to use and/or avoid nor was there a meal plan that was consistent with the hospitals ' menu. Review of the Diabetic diet revealed similar limitations.

INFECTION CONTROL PROGRAM

Tag No.: A0749

Based on observation, interview, and record review, the hospital failed to ensure dietary staff followed their policy and procedure for hand-washing/santizing when handling non-food items during the preparation of food. Diet 1 touched a book, then without washing/santizing hands prepared a plate of food. This failure had the potential for the transmission of infectious organisms to patients, staff and visitators.


Findings:


Review of the hospital's undated policy and procedure titled, "Gloves and Handwashing" on 5/25/16
indicated the following:

I. Purpose:
To reduce the risk of infection, foodborne illness, and cross-contamination by removing bacteria and viruses for hands.


Guidelines:
Hands should be cleaned.
-Immediately before engaging in food preparation.
-Afer engaging in other activities that contaminate hands.


During an observation on 5/25/16, at 8:35 a.m., of the patient cafeteria and food tray line preparation, Diet 1, while at the cash payment area, picked up a booklet of food prices with bare hands. Diet 1 then returned to the food service preparation and resumed plating and serving food with washing or performing any form of hand hygiene. During an interview with Diet 1 on 8/25/16 at 8:40 s.m., Diet 1 stated she should have washed her hands before resuming serving activity.


During an interview on 5/25/16, at 10:10 a.m., RNICP (Registered Nurse Infection Control & Prevention) indicated contamination of food with infectious organisms may occur if food handlers do not sanitize hands before plating food.