Based on 2021 Survey Data, F-Tag 812: Food Procurement was the second most cited deficiency on annual surveys and the 5th most cited overall. So far, in 2022, it has been the #1 deficiency cited on annual survey and the 4th most cited overall. (Source: S&C’s Quality, Certification and Oversight Reports (QCOR))

The State Operations Manual Appendix PP [Appendix PP – November 22, 2017 (] states facilities must “Procure food from sources approved or considered satisfactory by federal, state or local authorities” and also “Store, prepare, distribute and serve food in accordance with professional standards for food service safety.” In other words, food safety must be maintained through the entire process, from suppliers to receipt of deliveries, storage, through preparation, and to the resident’s tray.

The State Operations Manual [SOM ( pp 40-41] gives direction to the surveyors for the kitchen/food service observation. According to this document, the general objective is “to determine if the facility is storing, preparing, distributing, and serving food according to 42 CFR 483.35(h)(2) to prevent food borne illness.” This task is accomplished through the use of the Kitchen Observation Worksheet, which can be found at  Nursing Homes | CMS under “Survey Resources”. Surveyors are also directed to refer to the current FDA Food Code | FDA as well as the CDC’s Food Safety Home Page for additional guidance.


The Kitchen/Food Service Observation includes an initial brief tour of the kitchen, as soon as surveyors enter the facility, to include coolers and freezers for storage or labeling concerns, food prep spaces, handwashing facilities, and monitoring of staff hygiene practices. Ongoing follow up visit(s) to the kitchen later in the survey  will include a review of:

      • storage temperatures for both freezers and coolers, and review of logs to ensure monitoring is completed routinely
      • internal food temps for potentially hazardous refrigerated foods such as meat, fish, milk, eggs, and poultry
      • thawing temperatures for various food items
      • items in the coolers/freezers to ensure that they are appropriately covered and labeled, and that there is adequate space between items to allow for sufficient air flow.
      • Dry storage to check that items are stored off the floor and on surfaces that are clean and protected from contamination.

All food preparation and storage areas will be observed to ensure that there are no signs of water damage.


Once food prep begins, surveyors will monitor all stages of the process, from retrieval and handling of individual ingredients to the final presentation of the tray to the resident. Focus areas include:

      • Food temperatures during preparation, tray line and delivery to the resident to ensure that temperatures remain within regulations.
      • Ensuring food surfaces are thoroughly cleaned and sanitized after prep of any fish, meat, or poultry.
      • Food prep and service tools are used properly to prevent possible cross contamination of food items during service, and cleaned and sanitized thoroughly after use.
      • Cutting surfaces are sanitized between uses.
      • Proper infection control practices such as, but not limited to glove and hair net use and handwashing practices during preparation and on the tray line.
      • Food is covered during transportation and distribution to the resident.
      • Potentially hazardous foods that will be saved for later use are cooled within the appropriate time frames and to the correct temperature, then stored promptly to prevent the risk of foodborne illness.


Once food service is completed, monitoring will continue to ensure that the kitchen and all prep, service and dining implements are cleaned and sanitized appropriately. Dishwasher cycles will be observed to ensure that the dishwasher is operating in a manner that properly sanitizes the dishes and that appropriate logs are maintained. Chemical solutions will be checked for proper concentrations, and staff should be able to state what products are being used and the instructions for proper preparation of those products. After cleaning and sanitizing food service items, cleaned service items must be stored in a clean, dry location and not exposed to splash, dust or other contamination. Equipment logs will be checked to ensure that standards are being adhered to on an ongoing basis.


F812 also includes monitoring of storage areas on the units. Temperatures must be monitored and maintained within guidelines for any refrigerator that houses food items for resident use. Refrigerated items need to be labeled and dated to prevent the potential for foodborne illness.


Overall, F812 covers a broad array of items, each designed to ensure that food is stored, prepared, distributed and served safely.  Regular monitoring for compliance and education of staff is key to a successful outcome.

Make plans to join us on March 1st for the next webinar in our Survey Top Citations Series: Analysis of Top 10 Citations: Food Procurement.  Learn more and register



Cowritten By: Michele Harrison, RN, BSN and Judy Caffrey, RN
Proactive Medical Review

Learn more about the rest of the Proactive team.