Today’s Dietitian
Vol. 27 No. 9 P. 18
Food plays an essential role in long term care (LTC) settings. Dining services teams do more than provide three meals a day. The menus they create, the way they present food, and their collaboration with other team members all influence how older adults feel about the place they call home.
Behind the scenes, the procurement, storage, preparation, and sanitation of food in LTC facilities are jointly regulated by the CMS and state agencies.
Central to that oversight is F812, the federal regulation covering food procurement, storage, preparation, and sanitary practices. This massive federal tag covers so much of the dining services department that it’s also one of the primary reasons that LTC organizations are cited during annual surveys.
F812 applies primarily to skilled nursing facilities but also extends to other settings such as memory care communities and continuing care retirement communities. Each of these settings support vulnerable populations, and even small mistakes can have fatal consequences.
Addressing Frequent Violations and F812 Tag Citations
Understanding the full scope of what F812 covers reveals why it is challenging for dining teams to comply. To better understand the citations that LTC organizations often face, it’s helpful to break down exactly what this tag covers.
Food Procurement
Guidelines require facilities to purchase food from sources approved by federal, state, or local authorities.
Sanitation
The tag outlines requirements for the proper disposal of garbage, reinforcing the importance of cleanliness and sanitation in all aspects of dining services.1
Food Storage, Preparation, and Distribution
F812 also addresses how food is stored, prepared, and distributed. All handling must meet professional standards for food safety to minimize risk to residents. In addition, facilities must have clear policies for food brought in by visitors, such as family or friends, to ensure that outside food does not introduce safety risks. The most consistent challenges are within this area of regulation and may involve the following concerns:
- Recording temperatures. Regular temperature checks of refrigerators, freezers, and food are required and must be documented.
- Improper hand hygiene. Improper hand washing is one of the most common causes of outbreaks in dining rooms and restaurants. Organizations must provide adequate training and resources, have proper staffing, and offer sufficient time to implement proper handwashing.2
- Improper temperature control. In food service or display, temperature variances can occur, leading to bacterial and fungal outbreaks. For example, thawing meat at room temperature or leaving meat in standing water can cause pathogens to multiply.3
- Labeling and dating. Labeling and dating become tricky when you can no longer go by the “use by” date. If something has been opened, the use-by date would need to follow the facility’s policies and no longer be based on the sticker date. When food is being prepared in advance, there are use-by dates that need to be adhered to. It’s common and dangerous for LTC organizations to have items in their refrigerators that are not properly dated. It’s essential to remember that it only takes one product and one mislabeled date to cause an issue.
How Staffing and Training Gaps Lead to Food Safety Issues
Workforce shortages in LTC are well documented. The American Health Care Association’s 2024 State of the Sector Report, which highlights a survey of 441 nursing home providers, found that many nursing homes continue to struggle with employment postpandemic. A staggering 99% of nursing homes have open positions, and 94% shared that it was difficult to recruit new staff.4
It’s easy to see why dining services teams often face understaffing or high turnover. Often, dining services teams receive low pay. A job in this field requires being on your feet a lot, and it involves repetitive tasks.
To fill needed vacancies, LTC organizations often hire younger workers in high school or college. Utilizing younger staff can lead to frequent turnover as students graduate or find better opportunities. Populating dining services teams with younger workers can also lead to morale problems when workers do not feel invested in giving their best effort, as they may not see a sustainable career path or view their position as permanent. It’s also known that younger generations crave purpose in their work, more so than other generations.5
Gaps in staffing or frequent turnover have a noticeable impact on maintaining food safety standards. These issues hinder staff education. When you’re constantly interviewing and onboarding new team members, it’s nearly impossible to instill best practices in labeling, dating, and storage as second nature.
Language barriers also impact the ability to train staff properly, and it’s common to have dining team staff whose first language isn’t English.
Another barrier to adequate staff training—which impacts food safety—is dining services being undervalued by senior management. Too often, dining is seen as an expense because Medicare/Medicaid does not reimburse it. Additionally, leadership may not fully understand the scope, depth, and breadth of the impact of dining on an organization. For example, eating a balanced diet can reduce or eliminate the need for certain medications.6
The Reputational Risk to LTC Facilities
If you type “foodborne illness in senior living” into any search engine, dozens of news articles will pop up involving specific LTC communities failing health inspections, managing the impact of an outbreak, or restricting visitors.
When an LTC organization has a foodborne illness outbreak or fails an inspection, that lives in the public record.
Those social media posts, TV clips, news articles, and bad reviews can live online indefinitely and seriously impact how current and prospective residents and families perceive a community. In today’s landscape where food quality and choice are increasingly important, negative perceptions of dining services can greatly hinder a community’s ability to attract new residents.7
How to Prepare for Audits and Create Lasting Improvement
Understanding how food impacts resident well-being, an organization’s reputation, and staff operations—especially amid challenges with recruitment, retention, and training—can make compliance with F812 regulations feel overwhelming. However, having a compliant kitchen is possible. By implementing best practices, conducting mock surveys, and receiving leadership support, organizations can build dining teams that are not only compliant but are also proud of the experience they deliver to residents.
Practical Steps
Make a Checklist
With a good checklist, there is nothing you can’t do. For a morning checklist, a team lead would check temperatures of refrigerators and freezers, inspect all items in the fridge to make sure they’re properly labeled and dated, survey the outside to make sure all trash and debris are properly disposed of, and perform other tasks as required. An evening checklist would have similar items included.8
Ensure Staff Are Supported
You cannot expect a dining services team member to be successful at their job if they don’t have the right tools. Tools can be as simple as having adequate lighting in the kitchen and having labels and markers available for dating and labeling food. Resources can also include easy access to policies and reference guides.
Evaluate and Improve Training
Online training such as ServSafe9 certification is an effective way to educate dining staff on cooking temperatures, sanitation products, and other areas that fall under the F812 tag. There are also other ways to train dining teams. On a day-to-day basis a manager can stand next to team members and walk them through the best practices in the kitchen. Even a five-minute demonstration session can make staff feel more comfortable with a task and in asking questions when they need clarification.
Conduct Mock Audits
Mock audits help prepare staff for state surveys and provide an opportunity to identify minor issues before they escalate into major citations.
Mock auditors follow the flow of food from the loading docks to storage, through preparation, and finally to delivery to the resident. At every step, they observe and take notes, using the process to assess compliance and educate managers and staff along the way.
Even teams that are working hard to stay compliant can benefit from these walkthroughs. Every kitchen is a work in progress, and it only takes one mislabeled product to backslide into noncompliance. The most successful teams are those that don’t get defensive but instead take recommendations seriously and implement necessary changes.
Key Takeaways
LTC dining services teams that align their operations with F812 are doing more than achieving compliance, they’re protecting resident well-being, preserving the organization’s reputation, and communicating a culture of care across the residence.
While some challenges—like staffing shortages—require longer-term strategies, there are many actionable steps that teams can take in the short term. Bringing in a third-party consultant can provide immediate support through developing practical tools like checklists and routines, conducting mock audits, or creating education plans. Additionally, having a third-party make the case to leadership can be helpful when leadership may not understand the risks of noncompliance and the difficulty in navigating a highly regulated environment.
— Tracy Malloy, RD, LDN, CHC, CHPC, has 35 years of long term care experience. Her background includes a variety of clinical and operational positions, including food service director, clinical nutrition manager, district manager, corporate dietitian, and vice president of nutrition and dining services. In her current role at Friends Services Alliance Compliance Collaborative, she works with nonprofit organizations nationwide, primarily in the senior living field.
References
1. Food and nutrition services. 42 CFR § 483.60. Electronic Code of Federal Regulations website. https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-G/part-483/subpart-B/section-483.60. Published July 5, 2023. Accessed September 12, 2025.
2. Food worker handwashing in restaurants. Centers for Disease Control and Prevention website. https://www.cdc.gov/restaurant-food-safety/php/practices/handwashing.html. Published March 18, 2024. Accessed September 12, 2025.
3. Proliferation contributing factors. Centers for Disease Control and Prevention website. https://www.cdc.gov/restaurant-food-safety/php/investigations/proliferation-contributing-factors.html. Published March 25, 2024. Accessed September 12, 2025.
4. State of the sector: nursing home labor staffing shortages persist despite unprecedented efforts to attract more staff. American Health Care Association/National Center for Assisted Living website. https://www.ahcancal.org/News-and-Communications/Press-Releases/Pages/State-Of-The-Sector-Nursing-Home-Staffing-Shortages-Persist-Despite-Unprecedented-Efforts-To-Attract-More-Staff-.aspx. Published March 5, 2024. Accessed September 12, 2025.
5. Khosla S. How to attract gen z workers with purpose-driven workplaces. SHRM website. https://www.shrm.org/enterprise-solutions/insights/how-to-attract-gen-z-workers-with-purpose-driven-workplaces. Published January 15, 2025. Accessed September 12, 2025.
6. Hunter E. Food and drug interactions that older adults need to monitor. Pharmacy Times website. https://www.pharmacytimes.com/view/food-and-drug-interactions-that-older-adults-need-to-monitor. Published July 5, 2023. Accessed September 12, 2025.
7. Gresham T. Why dining matters in senior living—and what’s changing. Argentum website. https://www.argentum.org/why-dining-matters-in-senior-living-and-whats-changing/. Published April 16, 2025. Accessed September 12, 2025.
8. Tripoli C. The daily opening checklist. Restaurant Owner website. https://www.restaurantowner.com/public/The-Daily-Opening-Checklist.cfm. Accessed September 12, 2025. 9. ServSafe website. https://www.servsafe.com/. Accessed September 12, 2025.
