CMS Reminds Hospitals Of Their Nutrition Obligations

The CMS Center for Clinical Standards and Quality has issued a Quality & Safety Special Alert Memo regarding patient food and nutrition services.  Here is the Summary and the initial Discussion:

https://s3.documentcloud.org/documents/27926757/cms-memorandum-on-dietary-guidelines.pdf

REFERENCE: QSSAM-26-03-Hospital/CAH
DATE: March 30, 2026
TO: Hospital/CAH Providers
FROM: Centers for Medicare & Medicaid Services (CMS)
SUBJECT: Hospital Nutrition Service Obligations in Light of Updated Federal Nutrition

Memorandum Summary

This memorandum reminds hospital providers of their obligations related to patient food and nutrition services. On January 7, 2026, HHS and USDA released the Dietary Guidelines for Americans, 2025–2030 (DGAs), which place heightened emphasis on diet quality — including limiting ultra-processed foods, sugar-sweetened beverages, refined carbohydrates, and added sugars, while prioritizing whole and minimally processed foods. These updates reflect the latest federal nutrition policy and are encouraged to be used to inform patient nutrition services and related hospital protocols. Given the scale of Medicare’s investment in inpatient care, CMS has a responsibility to ensure that hospital food and nutrition services support high-quality, evidence based care and improved health outcomes.

Hospitals must comply with Conditions of Participation at 42 CFR §482.28, including ensuring menus and diets meet individual patient nutritional needs in accordance with recognized dietary practices, qualified dietitian oversight, maintenance of a current therapeutic diet manual, and integration of dietary services into Quality Assessment and Performance Improvement (QAPI) processes. As consistent with 42 CFR §482.28 and CMS guidance, hospitals should review and revise food and nutrition service policies, standard menus, therapeutic diet protocols, and food procurement practices to align with the 2025–2030 DGAs.

Discussion:
Diet Quality and Health Outcomes

The United States spends approximately $5 trillion per year on health care. Ninety percent of those expenditures are on patients with chronic disease. Since Medicare represents approximately 40% of health care spending on chronic health conditions in the United States, the impact on American taxpayers and the Federal deficit is significant.

Given these dynamics, it is an urgent priority for hospitals who treat Medicare patients to ensure their policies and practices provide those patients with high-quality and clinically appropriate dietary options. Emerging high-quality epidemiologic evidence strengthens the case for prioritizing minimally processed, whole foods in institutional settings. Large prospective cohort studies and updated systematic reviews have found that higher intake of ultra-processed foods is associated with increased risks of cardiovascular disease, type 2 diabetes, and all-cause mortality. For example, an updated 2025 dose–response meta-analysis found a 15% higher risk of all-cause mortality among individuals with the highest ultra-processed food intake.

A growing body of peer-reviewed evidence further demonstrates that diet quality—not simply caloric adequacy—substantially affects cardiometabolic outcomes, mortality, and chronic disease progression. High consumption of sugar-sweetened beverages has been associated with increased risk of type 2 diabetes, cardiovascular disease, and mortality in large prospective cohort studies and meta-analyses. Similarly, ultra-processed foods, including sweetened beverages and processed meats, have been associated with increased risk of diabetes and cardiometabolic disease.

Conversely, higher intake of whole grains and fiber-rich foods have been associated with lower risk of type 2 diabetes and improved long-term health outcomes. Replacement analyses further demonstrate improved outcomes when sugar-sweetened beverages are replaced with water, coffee, or tea.

Read the entire CMS CCSQ memo in pdf format at the hyperlink, above.