F812: Food Procurement, Storage, Preparation, & Sanitation Compliance

F812: Food Procurement, Storage, Preparation, & Sanitation Compliance

F812 Food Procurement, Storage, Preparation, and Sanitary Practices is the third most frequently cited deficiency for the 2025 fiscal year. Most citations have been issued at a scope and severity level of E or F; however, some facilities have been cited at the Immediate Jeopardy level. How well is your team prepared to comply with the requirements of F812?

Let’s review the regulatory requirements for F812, the survey process, common citation examples, and strategies to prevent non-compliance.

Regulatory Requirement

The facility must:

• Procure food from sources approved or considered satisfactory by federal, state or local authorities.
  • This may include food items obtained directly from local producers, subject to applicable State and local laws or regulations.
  • This provision does not prohibit or prevent facilities from using produce grown in facility gardens, subject to compliance with applicable safe growing and food-handling practices.
  • This provision does not preclude residents from consuming foods not procured by the facility.
• Store, prepare, distribute and serve food in accordance with professional standards for food service safety.

Regulatory Intent

The intent of this regulation is to ensure that the facility:

• • Obtains food for resident consumption from sources approved or considered satisfactory by Federal, State or local authorities;
  • Follows proper sanitation and food handling practices to prevent the outbreak of foodborne illness. Safe food handling for the prevention of foodborne illnesses begins when food is received from the vendor and continues throughout the facility’s food handling processes; and,
  • Ensures food safety is maintained when implementing various culture change initiatives such as when serving buffet style from a portable steam table, or during a potluck.

Foodborne Illness and Resident Vulnerability

The CDC estimates that approximately 48 million people in the U.S. contract foodborne illnesses annually. Elderly individuals are at heightened risk due to weakened immune systems, slower organ function, and the presence of chronic conditions. The effects of foodborne illnesses in this population can be severe, leading to prolonged illness, hospitalization, and increased mortality rates.

Policies and Procedures for Compliance

Facilities must have comprehensive policies addressing food procurement, storage, preparation, cooking, holding, and service. Key policy areas should include at a minimum:

• • Storage: Food Storage (dry, refrigerated, frozen, leftover foods), Nonfood Supply Storage, Chemical Storage, etc.
  • Food Preparation & Service: Food Handling: Eggs, Employee Sanitary Practices, Handwashing Procedures, Thawing Methods, Food Handling: Internal Meat Temperatures, Trayline and Meal Service Temperatures, Food Holding Temperatures on Food Service Line, Minimum Temperatures at Point of Service, Temperature and Time Controls, etc.
  • Sanitation: Use of Cutting Boards; Sanitation and Calibration of Thermometers; Equipment Cleaning Schedules; Dishwashing Procedures; Water Temperatures for Dish-machines, etc.

Note: This is not meant to be an all-inclusive list.

Survey Process (Critical Element Pathway – Form CMS20055)

Initial Kitchen Tour

During the recertification survey, inspectors conduct a preliminary kitchen tour to evaluate compliance with key safety and sanitation elements. Deficiencies in any of the following areas may result in an F812 citation:

• • Safe thawing of potentially hazardous foods.
  • Proper labeling and dating of refrigerated food items.
  • Prevention of cross-contamination in food storage.
  • Availability and use of dedicated handwashing stations.
  • Adherence to proper hand hygiene and glove use during food preparation.
  • Use of pasteurized eggs in undercooked dishes.
  • Maintenance of appropriate food storage and preparation temperatures.
  • Staff adherence to hygienic practices.
  • Proper use of hair restraints.

Follow-up Kitchen Review

Subsequent inspections will assess:

• • Storage Temperatures
  • Food Storage
  • Food Preparation and Service
  • Dinnerware Sanitation and Storage
  • Equipment Safe/Clean
  • Unit Refrigerators

Citation of F812

To cite F812, the surveyor’s investigation will generally show the facility failed to do any one or more of the following:

• • Procure, store, handle, prepare, distribute, and serve food in accordance with the standards summarized in this guidance; or
  • Maintain ‘potentially hazardous foods’ (PHF) and ‘time/temperature controlled for safety’ (TCS) foods at safe temperatures, at or below 41 degrees F (for cold foods) or at or above 135 degrees F (for hot foods) except during preparation, cooking, or cooling, and ensure that PHF/TCS food plated for transport was not out of temperature control for more than four hours from the time it is plated; or
  • Store raw foods (e.g., meats, fish) in a manner to reduce the risk of contamination of cooked or ready-to-eat foods; or
  • Cook food to the appropriate temperature to kill pathogenic microorganisms that may cause foodborne illness; or
  • Cool food in a manner that prevents the growth of pathogenic microorganisms; or
  • Utilize proper personal hygiene practices (e.g., proper hand washing and the appropriate use of gloves) to prevent contamination of food; and
  • Use and maintain equipment and food contact surfaces (e.g., cutting boards, dishes, and utensils) to prevent cross-contamination.

Examples of Immediate Jeopardy Citations

Dinnerware Sanitation & Storage: The facility failed to ensure that staff were able to verify the chemical sanitation level required to clean the main kitchen surfaces used for the preparation of residents’ food, increasing the potential risk of foodborne illnesses for the entire resident population who received meals prepared in the main kitchen; and failed to maintain the dishwasher sanitation rinse cycle temperature at a minimum of 180 degrees Fahrenheit per the manufacturer’s manual, increasing the potential risk of foodborne illnesses for residents who received meals on dishware cleaned in this dishwasher.

Unsanitary Foods Storage and Preparation: The facility failed to maintain a clean and sanitary kitchen to prevent cross contamination and the likelihood of foodborne illnesses to the residents who ate meals prepared from the facility’s kitchen.

Findings included: build-up of grease and residue on the outside of all refrigerators and all walk-in coolers; build-up of debris on the outside of all ice machines and brown substance noted on the inside the ice machine near the food prep station; trolleys being used to bring food items or dishes from one part of the kitchen to another had debris and food residue on them; all food preparation counters and stations noted with food residue from the breakfast meal service while lunch was being prepared; food residue noted on the steam table where tray covers and plates were stored for plating resident meals; a ladle that had been previously washed remained with a dried brown substance on it; and handwashing stations located by dishwashing sinks were out of order.

Inadequate Food Storage Temperatures: The facility failed to store foods at appropriate temperatures for 1 of 3 kitchen refrigerators reviewed for food safety. The facility’s failure was determined to be an immediate jeopardy situation because raw meat stored outside of an acceptable temperature was planned to be used for an upcoming meal. Findings included: during initial inspection of the kitchen an internal refrigerator thermometer read 45 degrees F. This refrigerator contained uncooked meat thawing, bacon, various salad dressings, cooked ham, cooked pulled pork, salami, pasteurized eggs, pasteurized cheeses and butter. The Dietary Director stated the fridge had problems staying cool for a few weeks. Stated she thought this was either due to the location of the fridge or due to a problem with the door not fully closing and staying closed. The next day, information was provided to the Dietary Director regarding the temperature being at 49 degrees F and she took no action. Dietary Director was requested to check the temperature of the uncooked beef which was observed to be 41.3 degrees F. Again, no action was taken after the temperature check.

Strategies for Avoiding F812 Citations

To maintain compliance and reduce the risk of citations, facilities should:

• • Provide ongoing staff education on sanitation protocols and regulatory requirements.
  • Implement routine audits of food storage temperatures, food handling practices, and dishwashing sanitation.
  • Utilize the Kitchen Observation Critical Element Pathway as an audit tool.
  • Establish a Quality Assurance and Performance Improvement (QAPI) plan to address deficiencies.
  • Conduct regular maintenance of kitchen equipment as per manufacturer recommendations.
  • Annually review and update the Dietary Policies & Procedures Manual, ensuring staff are trained on any changes.

By proactively addressing food safety and sanitation, facilities can enhance resident well-being and prevent regulatory violations related to F812.

Next steps: Join Proactive March 11, 2025 for in-depth F812 webinar training for your team as part of the Survey Smart series. Learn more and register. And ensure survey readiness everyday with Proactive’s Survey Ready Toolkit.