The Centers for Medicare and Medicaid Services (CMS) has released QSO-26-08-NH, providing important clarifications and flexibilities for Nurse Aide Training and Competency Evaluation Programs (NATCEP/CEP). The guidance is part of the agency’s broader effort to expand the certified nursing assistant (CNA) workforce and strengthen staffing in nursing homes.
While CMS maintains that all federal training requirements must still be met, the memo outlines several clarifications and reminders that providers and states should be aware of.
Key Takeaways:
- Clarification regarding fees for training and testing: CMS stressed that facilities cannot charge CNAs for training, materials, testing, or registry fees if they are employed or have an offer of employment. CNAs may also be eligible for reimbursement within 12 months of completing training.
- Minimum training requirements remain unchanged: Training must include at least 75 hours in total, including 16 hours of supervised practical training.
- More flexibility in training locations and for instructors: Training can occur in nursing homes, hospitals, or vocational settings, not just long term care facilities. Training can be delivered by RNs or LPNs under appropriate supervision, but instructors must have experience or training in teaching adults.
- Clarification on supervision requirements: “General supervision” does not require constant physical presence of an RN or LPN, but they must provide oversight and accountability.
- Remote technology is permitted: States may allow remote options for written exams and observation of skills, if all regulatory requirements are met. Facilities must ensure clear visibility and resident safety during any remote observation. Programs must obtain resident consent (written or verbal) for training participation, especially when using remote technology.
- States encouraged to improve access to training: CMS is promoting better state websites and visibility of CNA programs to help recruit new staff.
- Compliance and resident safety remain critical: Facilities are ultimately responsible for resident care and safety. Inadequate training or supervision can lead to survey deficiencies and enforcement actions.
Bottom Line
CMS is giving states and providers more flexibility to expand CNA training capacity, but expectations for quality, competency, and resident safety remain unchanged. Providers should review their training partnerships and internal practices to ensure they are leveraging these flexibilities while staying compliant.