This week’s Ftag of the Week on the CMSCG Blog is part of the Nursing Services regulatory group, F729 Nurse Aide Registry Verification, Retraining. As its title implies, this regulation looks at nurse aide training and the provider’s responsibilities for ensuring that nurse aides are qualified to work in their facilities, including that they have completed a nurse aide training and competency evaluation program (NATCEP/CEP).
One of the blanket waivers that the Centers for Medicare and Medicaid Services (CMS) enacted during the COVID-19 Public Health Emergency (PHE) related to some of the training and certification of nurse aides in order to address potential staffing shortages, but the requirements under F729 are excluded from any waiver. Providers are still responsible for ensuring that nurse aides are competent. Don’t forget that individual States may have differences in their expectations as far as checks and training, so it’s important to recognize both Federal and State requirements in this case.
Registry Verification Requirements
Nursing homes are required to receive registry verification that a prospective nurse aide has met competency evaluation requirements except for two circumstances. The first is that the provider would not be required to receive a registry verification if the individual is a full-time employee in a training and competency evaluation program that has been approved by the State. Those individuals who are participating in your facility’s nurse aide training program would fall into this type of exception.
The second exception is when the prospective employee can prove that he/she has successfully completed a State-approved program, but has not yet been included in the registry. In this case, the facility would still be expected to follow-up to ensure that the employee does actually become registered.
Either of these instances could be caused by the backlog of information that States need to catch up on and process, but follow-through on the facility’s part is important to ensure that they have done their due diligence in checking the registry and hiring only competent individuals. Providers are also expected to check every State registry that they believe could have information on an individual, so if the individual’s job history includes work history in multiple states, or there is a question on reciprocity qualification status, it would be wise to check all of the associated registries.
Of course, completion of the program at some point in history does not mean that satisfies the individual’s competency and training program requirements. If a prospective nurse aide has not been employed to provide nursing/nursing-related services within the past 24 consecutive months, then he/she would be required to complete a new program.
The employment must have been financially compensated, and per the Federal requirements, can be as little as one documented shift of 8 consecutive hours within that past 24-month time period. If the individual can provide documentation that verified he/she performed paid nursing/nursing-related services, including ADL assistance (not necessarily in a nursing home) to meet those requirements, then he/she does not need to participate in a new program.