“Storing, preparing and distributing food under sanitary conditions” otherwise known as F 371 is one of the most feared tags in dietary. This tag continues to make its way near the top as one of the most commonly cited deficiency. What determines if a facility is in compliance with F 371? The Centers for Medicare and Medicaid Services (CMS) has specific guidelines for surveyors to determine compliance when doing their annual survey.

Determination of compliance with F 371:

• Did the facility procure food from approved sources?
• Did the facility properly store, prepare, distribute and serve foods for residents’ consumption?

Criteria for compliance with F 371:

• The facility must procure, store, handle, prepare, distribute and serve food to minimize the risk of food borne illness
• The facility must maintain PHF/TCS (potentially hazardous foods/time, temperature control for safety) food at safe temperatures, at or below 41°F or at or above 135°F during storage
• Cook food to the appropriate temperature and hold PHF/TCS foods cold or hot
• The facility must utilize proper hand washing and personal hygiene practices to prevent food contamination
• The facility must maintain equipment and food contact surfaces to prevent food contamination

Non-compliance with F 371 may include, but is not limited to, one or more of the following:

Failure to:

• Procure, store, handle, prepare, distribute and serve food in accordance with the standards summarized in the guidance
• Maintain PHF/TCS foods at safe temperatures, at or below 41°F (for cold foods) or at or above 135°F (for hot foods)
• Ensure that PHF/TCS food plated for transport was not out of temperature control for more than four hours.
• Store raw foods properly to reduce the risk of contamination of cooked or ready-to-eat foods
• Ensure that foods are cooked to the appropriate temperature and cooled properly to prevent food borne illness

Actual or potential harm for non-compliance with F 371 include:

• Food borne illness
• Ingestion or potential ingestion of food that was not procured from approved sources, prepared, distributed or served under sanitary conditions

A level 4 deficiency is the most severe. This is considered to be immediate jeopardy and requires immediate correction.  It is defined as: “has allowed/caused/resulted in, or is likely to cause serious injury, harm, impairment, or death to a resident." An example of a Level 4 deficiency would be:

• A roast thawing on a plate in the refrigerator had bloody juices overflowing and dripping onto uncovered salad greens on the shelf below. The contaminated salad greens were not discarded and were used to make salad for the noon meal.

A level 3 deficiency is actual harm that is not immediate jeopardy. An example of a Level 3 deficiency would be:

• An outbreak of nausea and vomiting occurs in the facility related to the inadequate sanitizing of dishes and utensils.

A level 2 deficiency is no actual harm with potential for more than minimal harm that is not immediate jeopardy. Examples of a Level 2 deficiency would be:

• Food service workers sliced roast pork on the meat slicer. The meat slicer was not washed, rinsed, and sanitized after usage. During the dietary service system assessment, two days later, the surveyor observed the meat slicer soiled with dried meat underneath the blade. The facility failed to educate and train staff on how to clean and sanitize all kitchen equipment.
• During the tour of the kitchen, two food service workers were observed on the loading dock. One was smoking and the other employee was emptying trash. Upon returning to the kitchen, they proceeded to prepare food without washing their hands.

The food service manager must be aware of all staff practices and make sure all food is handled safely. Make sure there is proper orientation of new employees in regards to food handling practices. All employees need thorough in-service training by the food service manager or dietitian on all aspects of F371 to assure compliance. Conduct routine “mock surveys” to keep your operation in tip top shape. These “mock surveys” can keep surprises from happening when the surveyors enter your department. Be proactive when it comes to food safety to keep F371 violations away from your kitchen.