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Nurse Aide Training and Competency Question Follow-up

During the member call on December 8, members provided some questions that required additional research. These questions stemmed from CMS’ discussion on the Kansas City Regional Office call related to nurse aides no longer being able to challenge a competency evaluation without first completing a nurse aide course.

1. Is there a timeframe that someone completing a 75-hour course must successfully complete the competency examination without having to retake the 75-hour course? For example, if I completed a 75-hour course 2 years ago, but have not taken the examination am I still eligible to complete the exam?


A – There is no federal or state rules regarding Nurse Aide Training and Competency Evaluation Programs (NATCEP) that addresses a timeframe  regarding successful completion of a state approved course and the length of time to competency testing.

As a reminder – nursing homes (according to both State rules and Federal Regulations) who employ a person who has not completed a 75- hour course and successfully completed a competency evaluation must ensure that the temporary nurse aide has had training and is competent to perform tasks based on resident needs. This person can only be employed in a nurse aide position for a period of 4 months while they take the NATCEP.

2. Is someone able to challenge the test if they were previously certified (completed the 75-hour course and successful completion of the exam) but had a lapse in employment due to not working in a nursing home in 24-months? Or would they be required to complete another 75-hour course before taking the test?

A – The individual would need to complete a competency evaluation (skills and written test) to be listed as active on the nurse aide registry again. If an individual can provide a job description from a similar position as a nursing home (such as a dementia unit in Assisted Living Programs, med/surg unit of a hospital, etc) it can be submitted for consideration to DIAL to maintain active status on the registry.

3. If an individual previously challenged the test and successfully passed without completing the 75-hour course, will they be grandfathered in? Or will nursing homes need to ensure that they’ve completed a 75-hour course in addition to being on the registry?

A - DIAL is unsure what approach CMS will take when/if they enforce the requirement of a state approved 75-hour course before being active on the registry. According to CMS Kansas City Regional Office staff, they are unsure how these rules will be communicated to States.