Please Note: This article has been updated several times as the Indiana Department of Health (IDH) has clarified several components of the orders. Please see below for a summary of the updates, which are then incorporated into the longer article below.
- On October 27, this article was updated to provide clarification regarding online classroom hours, which are now permitted (whether for the full 30 hours or a hybrid approach) so long as advance or concurrent notice is provided to ISDHLTCTrainingPrograms@isdh.in.gov.
- On October 30, the emergency orders in this article were updated, as the orders now state that any person who completes the modified CNA training under the orders are only authorized to work as a CNA in Indiana-licensed comprehensive care facilities and residential care facilities (licensed assisted living). The intent of adding this language to both emergency orders is to ensure that the new pathways to becoming a CNA benefit long-term care facilities and their workforce.
- On November 6, this article was updated as IDH issued a third (3rd) order to address regulatory limitations on training Personal Care Attendants (PCA) and Temporary Nurse Aides (TNA) as full CNAs in facilities that are banned from nurse aide training. The IDH Order Authorizing Abbreviated Training of Certified Nurse Aides in Facilities Subject to CNA Training Bans utilizes waiver authority in the Social Security Act to permit training in facilities subject to CNA training bans under certain conditions. See more below. In addition, the IDH corrected an omission in the PCA/TNA to CNA Order ensuring that TNAs can also take advantage of the abbreviated training.
The IDH has issued three orders to reduce the number of CNA training hours with the addition of COVID-19 specific resident care procedures, provide a process for how PCAs and TNAs can be trained as CNAs, and authorize the training of PCAs and TNAs as CNAs in facilities that are subject to CNA Training Bans so long as that training is performed by an approved CNA training program.
Reduction in CNA Training Hours and COVID-19 Specific RCPS
The first order includes additional waivers of state regulation at 410 IAC 16.2-3.1-14(c) regarding CNA training hours and programming. The order and waivers are as follows:
- The minimum number of training hours for a person to become a CNA is 75, reduced from 105.
- No less than 2 hours of the required 30 classroom instruction hours must be focused on COVID-19 prevention, control and remediation.
- With the reduction to a minimum of 75 training hours, the supervised clinical experience is now a minimum of 45 hours. Of these 45 hours, a minimum of 24 hours must be direct supervised practical training in a comprehensive care facility and 1 of those 24 hours must focus exclusively on COVID-19 prevention, control and remediation.
- “Directly supervised practical training” means training in which the trainee demonstrates knowledge while performing tasks on an individual under direct supervision of a registered nurse or a licensed practical nurse. These hours shall consist of normal employment as a nurse aide under the supervision of a licensed nurse.
- The 1 hour of direct supervised practical training on COVID-19 prevention, control and remediation should focus on PPE and hand hygiene as discussed in IDH’s Infection Control Standard Operating Procedure.
With 24 of the 45 hours of direct supervised practical training required in a comprehensive care facility, the remaining 21 hours are permitted to be in a hospital, residential care facility or simulation laboratory. IDH has stated it will entertain waivers on case-by-case basis for undue barriers to meeting the 24 hour training requirement in a comprehensive care facility. Facilities and training partners should contact Matt Foster, firstname.lastname@example.org, for assistance with specific cases.
Finally, the emergency order states that any person who completes the modified CNA training under the order is authorized to work legally as a CNA, once eligible to do so, only in Indiana-licensed comprehensive care facilities and residential care facilities (licensed assisted living). As state above, this language was added to ensure the pathway benefits long-term care facilities and their workforce.
PCA and TNA Pathway to Certified Nurse Aide
The second order permits any person who became a registered Personal Care Attendant (PCA) or a Temporary Nurse Aide (TNA) to become a CNA under an expedited training program. Due to federal law concerning bans on nurse aid training by or in facilities with certain regulatory records, the pathway for PCAs and TNAs is different depending on this status as a “banned facility”. IDH issued this third order, relying on federal law that permits certain waivers to the nurse aid training ban, to permit PCAs and TNAs to be trained in a banned facility so long as the training is provided by an approved nurse aide training program (which could be another facility or a third-party non-facility based training program).
The following are the steps required for a registered PCA or TNA to become a CNA. Each step has additional instruction as for PCAs and TNAs that have been or will be training in facilities banned from nurse aide training.
- The 8 hours that a PCA or TNA completed to become a PCA are credited to the hours required for the PCA or TNA to train as a CNA.
- Banned facilities: If a PCA or TNA completed these 8 hours from instruction by and in a banned facility, then these 8 hours must be repeated by an approved nurse aide training program (another facility-based or non-facility based program). The repeat of these 8 hours can be done in the banned facility so long as they are under the direction of an approved nurse aide training program.
- Either a PCA or TNA candidate must complete 18 additional hours of training, consisting of 15 hours of classroom instruction and 3 hours of skills checkoffs. The training must follow the Expedited CNA Training for PCAs and TNAs curriculum, which is Appendix A to the order (this curriculum is built from the existing CNA program). The 15 hours of classroom instruction includes two (2) hours of COVID-19 focused Infection Prevention and Control, which should focus on IDH’s Infection Control Standard Operating Procedure (with an emphasis on the Return to Work Guidance), Use of Face Shields or Protective Eyewear Goggles, and Visitation Guidelines for Long-Term Care Facilities.
- Banned facilities: Any of these hours from instruction by and in a banned facility must be repeated by an approved nurse aide training program (another facility-based or non-facility based program). These hours can be done in the banned facility so long as they are under the direction of an approved nurse aide training program.
- When either a PCA or TNA candidate has completed the additional 18 hours and accrued at least 49 hours of facility-based work, the candidate is deemed to have met the 75 hours of training required to become a CNA. Candidates must possess documentation of all training and required work hours before sitting for the CNA testing and skills examination.
- Banned facilities: Accrual of the 49 hours of facility-based work in a banned facility should take place after the PCA or TNA candidate has been partnered with an approved nurse aide training program (another facility-based or non-facility based program). This means that work hours prior to that time do not count towards the 49 hours that are paired with the 26 hours of training, for a total of 75 hours. PCAs and TNAs in banned facilities should be able to accrue the 49 hours quickly as they progress through the 26 hours of required training.
Like the first order, this emergency order also includes language stating that individuals who complete this pathway may only work as a CNA in long-term care facilities.
IDH has been clear to state that any person, regardless of the pathway they choose, that becomes a CNA under these orders will remain a CNA after these orders expire even if the minimum training hours are increased again to 105.
Beyond issuing these Waivers, IDH has reinterpreted one of its rules in a way that should provide CNA training programs additional relief. Effective immediately, some or all of the required 30 hours of classroom instruction may be conducted online. In addition, IDH will not require pre-approval of new online or hybrid instruction so long as IDH receives advance or concurrent email notice of any change at ISDHLTCTrainingPrograms@isdh.in.gov. This reinterpretation will remain in effect following expiration of the public health emergency.
Please contact Zach Cattell, email@example.com, with questions.