Home Health Aide Training Requirements, 2011

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Home Health Aide Training Requirements, 2011 Background Federal legislation (42 CFR 484.36) requires that Medicare-certified home health agencies employ home health aides who are trained and evaluated through training programs approved by their state. Federal regulations require that these training programs consist of at least 75 hours of training, including at least 16 hours of supervised practical or clinical training and 12 hours of continuing education per 12 month period. Federal regulations also list the subject areas and skills to be taught, outline the qualifications for approved trainers and define the competency evaluation process. In its recent report on the adequacy of the healthcare workforce for older Americans (Retooling for an Aging America, 2008), the Institute of Medicine (IOM) recommends that Federal requirements for the minimum training of certified nursing assistants (CNAs) and home health aides should be raised to at least 120 hours and should include demonstration of competence in the care of older adults as a criterion for certification (Recommendation 5-1). PHI Findings Less than one-third of states require more than the minimum federal standard of 75 hours for Home Health Aide training, as summarized in the accompanying chart: 34 states and the District of Columbia do not require more than the minimum federal standard of 75 hours, a standard which has not been changed in 20 years. 16 states exceed the federal minimum for training hours, but only 6 of those meet the standard suggested by the IOM of 120 hours. 14 states require more than the minimum 16 hours of clinical training, with required clinical hours ranging up to 80 hours. Of the 16 states exceeding the federal standard, 10 require Home Health Aides to be Certified Nurse Aides. An additional 4 states allow CNAs to become certified Home Health Aides with supplementary training. Federal standards for Certified Nurse Aide training have also remained at 75 hours for the past 20 years. However, 30 states and the District of Columbia have exceeded these minimum standards for Certified Nurse Aide training hours. By comparison, relatively little progress has been made towards meeting the improved standards for Home Health Aide training recommended in the IOM report.

Home Health Aide Training Requirements, 2011 Hours State Training Hours 120+ hours (6 states) 76 119 hours (10 states) 75 hours (34 states + District of Columbia) Clinical Hours Maine* 180 70 Alaska* 140 80 California** 120 20 Idaho* 120 40 Illinois 120 40 Wisconsin* 120 32 Kansas** 110 45 Rhode Island* 100 20 New Hampshire* 100 60 Hawaii* 100 70 Maryland* 100 40 Montana** 91 25 Wyoming** 91 16 Washington* 85 50 Vermont* 80 30 New Jersey 76 16 Alabama 75 16 Arizona 75 16 Arkansas*** 75 16 Connecticut* 75 16 Colorado 75 16 Delaware 75 16 D.C. 75 16 Florida 75 16 Georgia 75 16 Iowa 75 16 Indiana 75 16 Kentucky 75 16 Louisiana 75 16 Massachusetts 75 16 Michigan 75 16 Minnesota 75 16 Mississippi 75 16 Hours 75 hours (cont d) State Training Hours Clinical Hours Missouri 75 16 Nebraska 75 16 Nevada 75 16 New Mexico 75 16 New York 75 16 North Carolina* 75 16 North Dakota 75 16 Ohio 75 16 Oklahoma 75 16 Oregon 75 16 Pennsylvania 75 16 South Carolina 75 16 South Dakota 75 16 Tennessee 75 16 Texas 75 16 Utah 75 16 Virginia 75 16 West Virginia 75 16 *Home Health Aides must be Certified Nursing Aides and have completed the CNA training and competency evaluation **Certified Nurse Aides may be dual certified as Home Health Aides with additional training ***Home Health Aides may become Certified Nurse Aides with no additional training provided successful completion of the CNA competency evaluation. www.phinational.org/policy

State Citations for Home Health Aide Training Requirements November 2011 Alabama: Follows the Federal Code of Regulations: CFR Title 42, Vol. 3, 484. Alaska: Alaska Administrative Code, Title 7, 12.519. Arizona: Arizona Revised Statutes, Title 36, Article 2, 36.2939 (B.2.a). Arkansas: Follows Federal Code of Regulations: CFR Title 42, Vol. 3, 484. California: California Code of Regulations, Title 22, Division 5, Chapter 6, 74747. Colorado: Code of Colorado Regulations, 10 CCR 2505 10 8.525. Connecticut: Connecticut Department of Public Health Regulations, Public Health Code, Title 19 13 D69. DC: District of Columbia Municipal Regulations, Title 22 B, Chapter B39, 3915. Delaware: Delaware Administrative Code, Title 16, 4406. Florida: Florida Administrative Code, Rule Chapter 59A 8.0095. Georgia: Follows Federal Code of Regulations: CFR Title 42, Vol.3, 484. Hawaii: Hawaii Administrative Rules, Title 11, Chapter 97, Section 1. Idaho: Idaho Administrative Code, IDAPA 16.03.07. Illinois: Illinois Administrative Code, Title 77, 245.70. Indiana: Indiana Code 16 27 1.5 1 Iowa: Follows Federal Code of Regulations: CFR Title 42, Vol. 3, 484. Kansas: Kansas Administrative Regulations 28 51 100. Kentucky: Follows Federal Code of Regulations: CFR Title 42, Vol.3, 48

Louisiana: Follows Federal Code of Regulations: CFR Title 42, Vol.3, 484. Maine: Code of Maine Rules, 10 144, Chapter 119. Maryland: Code of Maryland Regulations, Title 10.39.01.08. Massachusetts: Follows Federal Code of Regulations: CFR Title 42, Vol. 3, 484. Michigan: Follows Federal Code of Regulations: CFR Title 42, Vol. 3, 484. Minnesota: Minnesota Administrative Rules, 4668.0100. Mississippi: Follows Federal Code of Regulations: CFR Title 42, Vol. 3, 484. Missouri: Follows Federal Code of Regulations: CFR Title 42, Vol. 3, 484. Montana: Montana Department of Public Health and Human Services, Policies and Procedures, State Certification of Competency for Home Health Aides. Nebraska: Nebraska Administrative Code, Title 175, 14 006.04G5. Nevada: Department of Health & Human Services, Medicaid Service Manuals, 1400. New Hampshire: New Hampshire Code of Administrative Rules, Chapter He W 553. New Jersey: New Jersey Administrative Code, Title 13:37 14.4. New Mexico: New Mexico Administrative Code, 7.28.230C. New York: New York Codes, Rules, and Regulations (NYCRR), Title 10, 700.2. North Carolina: Division of Medical Assistance, Medicaid Clinical Coverage Policies and Provider Manuals, Clinical Coverage Policy No.: 3A (6.2). North Dakota: North Dakota Administrative Code, 33.03.10.18. Ohio: Ohio Administrative Code, 5101:3 Division of Medical Assistance, Chapter 12. Oklahoma: Oklahoma Administrative code, Title 310, 677 11. Oregon: Oregon Administrative Rules, 410 127 0020. Pennsylvania: Follows Federal Code of Regulations: CFR Title 42, Vol. 3, 484. Rhode Island: Rhode Island Rules and Regulations, R23 17 HNC/HC/PRO.

South Carolina: Follows Federal Code of Regulations: CFR Title 42, Vol. 3, 484. South Dakota: South Dakota Administrative Code, 67 16:05:01. Tennessee: Rules of the Tennessee Department of Health, Board of Licensing Health Care Facilities, Chapter 1200.08.26. Texas: Texas Administrative Code, Title 40, Part 1, Chapter 97, Sub Chapter D, 97.402. Utah: Follows Federal Code of Regulations: CFR Title 42, Vol. 3, 484. Vermont: Regulations for the Designation and Operation of Home Health Agencies, Part X, 10.1. Virginia: Virginia Administrative Code, Title 12, Agency 30, Chapter 50, Section 160. Washington: Washington Administrative Code, Title 24, 335 015 23. West Virginia: Follows Federal Code of Regulations: CFR Title 42, Vol. 3, 484. Wisconsin: Wisconsin Administrative Code, Chapter DHS 129, Certification of Programs for Training and Testing Nurse Aides, Medication Aides and Feeding Assistants, Subchapter II. Wyoming: Wyoming Department of Health, Aging Division, Rules for Program Administration of Home Health Agencies, Chapter 9.