02.15.18

The Truth Behind Home Health Aide Certification Requirements

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Home health aides (HHAs) play an important role in maintaining the health and well-being of the elderly, ill, and disabled.  This role varies from changing bandages and distributing medications, to grocery shopping and helping to pay bills.  Unlike other health care workers who are located in a health care facility, HHAs enter patient homes and thus have access to the most intimate parts of peoples’ lives and are often not supervised.  Because of this, it is imperative that HHAs are screened and that they go through a rigorous training process.

Home health aides usually work with patients who need more extensive physical and or medical care than a typical family can provide.  There is no formal education requirement (including a high school diploma) to secure a position as an HHA, although certificate and training courses are available from many postsecondary institutes.  Some HHA and hospice agencies, however, may require a high school diploma from their employees.

According to the US Bureau of Labor Statistics, HHA educational requirements vary depending on the employer.  Aides who work for organizations that receive funds from Medicare or Medicaid must complete formal training, while those who work for private companies are not required meet these obligations.  More experienced aides, such as certified nursing assistants (CNAs) and licensed practical or registered nurses, often provide on-the-job training for new aides.

Federal Requirements

Throughout the US any home health agency that accepts Medicare must employ certified home health aides.  Federal law states that HHAs working at a CMS (Centers for Medicare and Medicaid Services), must have 75 hours of training, including 16 hours of on-the-job training. This is the minimum number of required hours, and states can then choose if they want to license HHAs working in the state and if any additional training is needed.  However, it is important to distinguish facilities that accept CMS and those that do not.  Private companies that do not accept Medicare do not have certification requirements.

State Requirements

As mentioned above, HHA certification requirements vary greatly by state.  In Wyoming, there is no HHA specific training program or designation.  In order to work as an HHA, one must complete an approved CNA program.   The state of Wyoming then sets standards for how home health agencies train their home health aides. State law requires home health agencies to provide 16 hours of additional training upon being hired in the first two weeks.

In Wisconsin, potential HHAs must complete a CNA training program and then successfully complete an exam and a background check.  To be a CNA in Wisconsin requires a minimum of 120 total hours of training, including 32 clinical hours.

In Vermont, to work as an HHA an applicant must first be a Licensed Nursing Assistant (LNA).  The LNA training program includes 80 hours of total training, with 30 hours of clinical training.  After the training, all LNAs must pass a state exam and register with the state.

Washington, DC Requirements

Washington, DC only requires the bare minimum number of training hours (75), including 16 hours of on-the-job training.  Many states require more than this bare minimum and some states even require formal training such as a CNA or another nursing degree or certification to be an HHA.   In Washington, DC, in order to be certified, home health aides must successfully complete a training program, pass a competency exam issued by the District of Columbia Board of Nursing, pass a criminal background check, and submit an application along with a fee to the District of Columbia Board of Nursing.  However, for private companies that do not accept Medicare, these certification requirements do not apply.

The District of Columbia Home Health Aide certification by examination was established in July 2012 with the final publication of the Home Health Aide Regulations.   The regulations were derived from the revised Health Occupations Revisions Act of 2009, which place Nursing Assistive Personnel under the authority of the Board of Nursing.  The District of Columbia Home Health Aide Regulations were last revised and amended in September 29, 2017.

Many HHAs could be “waived in” or “grandfathered in” in the past, meaning they could waive the examination to be certified as an HHA. There are now four ways to be certified as an HHA in Washington, DC: (1) Certification by examination, (2) certification by endorsement, (3) certification by renewal, and (4) reactivation of certification.   The examination has 2 parts: a written section and a skills section.  HHA certifications expire October 31st of every odd numbered year.

There has been a history of fraudulent HHA applications in Washington, DC with HHA applicants submitting certification applications directly to the Board of Nursing themselves.  Many applicants have submitted fraudulent educational certificates and applications.  Because of this, the Board now requires applications to come directly from the HHA’s employers, and for those applying to take the HHA examination, the HHA schools must send lists of graduates to the processing unit.

Due to the nature of their responsibilities and the Importance of their roles, HHAs should be thoroughly trained and vetted, arguably more than health care workers who work in health care facilities.  However, this is not always the case due to relaxed training and education requirements that vary from state to state across the country.  This is especially worrisome in the nation’s capital, which has some of the least restrictive requirements for HHAs, and a history of loopholes, such as the grandfather clause, that allowed for unqualified and unverified HHAs to work in the District.

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The views reflected in this blog are those of the individual authors and do not necessarily represent those of the O’Neill Institute for National and Global Health Law or Georgetown University. This blog is solely informational in nature, and not intended as a substitute for competent legal advice from a licensed and retained attorney in your state or country.

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