This week’s Ftag of the Week is F947 Required In-Service Training for Nurse Aides, which is part of the Training Requirements regulatory group. The Federal regulation requires that nurse aides receive at least 12 hours of in-service training annually, but states have varying requirements for education that exceed this minimum requirement may be needed based a number of areas such as a changing resident population that require specialized education. Additionally, the Interpretive Guidance (IG) clearly states that 12 hours is the minimum number of training hours, but training must be sufficient to ensure the continuing competence of nurse aides, which may require more than 12 hours a year.
The requirement under F947 states that training must include dementia management and resident abuse prevention training. For staff that will be working with cognitively impaired individuals, care for these individuals must be specifically provided as well. Additionally, in Phase 1, In-service training for nurse aides was required to address individual areas of weakness that are determined by nurse aides’ performance reviews. Surveyors are guided to identify how in-service education has addressed identified areas of weakness on performance reviews and how the facility evaluates nurse aides’ performance to determine where additional education and training is needed. Effective in Phase 2, the in-service training also needed to address the unique needs of a facility’s resident population based on the Facility Assessment and as determined by facility staff.
During survey, surveyors do not need to find a negative outcome to cite the facility under F947. The surveyors will be reviewing the adequacy of the in-service program not just by looking at hours of completed education, but also by observing nurse aides. These observations may indicate that there are skill deficiencies that could be a result of an inadequate training program or that the nurse aides’ performance reviews are inadequate, such as by observing staff working with residents in a way that indicates a training need. During resident, representative and staff interviews, surveyors may identify areas where training may be needed, including when a surveyor has identified a concern and asks a nurse aide about the relevant education and skills competencies he/she has received. This is the time to take a hard look at your Inservice Education Program for your nurse aides and address any areas of weakness that are identified in providing necessary education and doing follow-up quizzes or discussion to assess staff understanding of the education provided. While you are taking a look at the associated systems, take a look at the last time each nurse aide had a performance evaluation (hopefully it is not from 2016 or earlier) that was accurately completed. What do we mean by this? A nurse aide, nor any of us, are so “perfect” of an employee that only time and attendance need improvement. Educate staff who are responsible for completing the performance evaluations on the need to be honest in their annual review of each nurse aide. For example, if a nurse aide’s manner is rushed and upsets the cognitively impaired residents she is responsible for, develop a performance improvement plan for this area – especially if the aide is too frequently reporting a bruise after providing care.