On April 7, 2022, the Centers for Medicare & Medicaid Services announced that the waiver option that created clinical caregiving roles known as Temporary Nurse Aides (TNAs) and Personal Care Aides (PCAs) will expire at the federal level on June 6, 2022. 

Individual state regulations may vary. TNAs and PCAs have until Oct. 6, 2022, unless modified at the individual state level, to complete all required training and to successfully pass their respective state’s competency test. Nearly 300,000 students as of May 2022 have completed the American Health Care Association’s TNA course, which indicates that there is significant interest in clinical careers. 

The recruitment, development and retention of quality, healthcare-focused caregivers remain top priorities for skilled nursing and long-term care providers. In my November 2021 editorial, I suggested creative strategies that could be enacted by federal and state governing entities that would expand opportunities for those seeking clinical careers as CNAs. These ideas are still relevant and should be considered for inclusion in future regulations.   

This article outlines the steps for providers to create a pathway for TNAs and PCAs to transition to fully licensed/certified nurse aides.

1. Know your state’s specific regulations for nurse aide licensing & certification

States that recognize and approve the use of TNAs and PCAs

• States that have granted TNAs and PCAs modified training requirements
• States that require TNAs and PCAs to complete a traditional, approved Nurse Aide Training Program (NATP) 
• States that allow candidates to challenge the license test without the completion of a formal nurse aide training course

States that did not approve the use of TNAs and PCAs

• Candidates are required to complete a traditional, approved Nurse Aide Training Program (NATP) 
• Programs must incorporate an approved nurse aide training curriculum 
• Facilities must apply and be approved to become a NATP clinical site
• Instructor must submit credentials and be approved by the state

For unanswered questions, I recommend contacting the organization that manages the nurse aide registry for your state.

1. Understand the components of required pre-licensure training for TNAs/PCAs

TNAs and PCAs must have proof that they completed the following training elements according to the regulations for the state they seek to be licensed in:

• Proof of or a certificate of completion from a temporary nurse aide or personal care aide training course that incorporates the minimum required hours for all mandatory topics outlined by CMS in their waiver guidance. The free AHCA TNA course has both 8-hour and 16-hour versions to address state-specific requirements.
• Lab and skills competency training typically conducted at their facility of employment led by a state-licensed RN instructor. 
• Check-off documentation demonstrating their skills competencies by a state-licensed RN for all mandatory skills. 
• Documentation of their on-the-job work experience hours delivered under the supervision of a state-licensed RN.
• Documentation of the completion of additional training requirements based on each individual state’s mandates. Many of these are focused on theory training and not skills, so they could be offered online.     

1. Evaluate options for providers to sponsor TNAs/PCAs to complete all required training  

• Hybrid Online Model for an approved Nurse Aide Training Program – clinical skills and lab portions of the course are delivered in-person and onsite with preceptors. Theory portion of the course is delivered 24/7 online. 
• In-Person Model for an approved Nurse Aide Training Program – both clinical skills and theory components are delivered in person on a scheduled basis at a provider’s facility or community college.
• TNA to CNA Bridge Course Model – applicable in states that have modified nurse aide training requirements for TNAs and PCAs. Course is delivered in person or online focusing on the theory components only. This allows flexibility to reduce the mandatory training hours while granting students full access to the complete course materials. The state license/certification competency tests are not modified or reduced; therefore, understanding all topics is important. Granting credit for the TNA and PCA basic training course as well as on-the-job work experience can also reduce the course price.     
• TNA to CNA Test Prep Model – a study guide format at an affordable price that equips TNAs and PCAs with critical materials and links to skills checklists. This service is a subscription model with unlimited access, which may be valuable in states that are experiencing delays in the availability of testing center appointments. This option is also viable in challenge states and those where no additional formal training is required to prepare TNAs and PCAs to successfully pass the license test.  

Periods of significant challenges like what we have all experienced during this recent pandemic also can stimulate an environment of fresh thinking and creative approaches. Through collaboration, cooperation and innovation, we have a real opportunity to build upon a tradition of ensuring that caregivers complete quality training requirements. We are blessed every day to have an opportunity to engage with compassionate and committed leaders from the American Health Care Association, AHCA state affiliates, state regulators, provider facilities and especially the healthcare heroes who pursue caregiving careers that train with our solutions.     

John P. Reinhart, CPA, MBA, is a serial entrepreneur and an innovator specializing in digital health and age tech. John is the co-founder and president of Academic Platforms. Academic Platforms is the exclusive partner for the American Health Care Association in providing online clinical education focused on nurse aide and CNA pre-licensure training at cnaonline.com. He is also an executive-in-residence with the National Institute on Aging, which is part of the National Institutes of Health.

The opinions expressed in McKnight’s Long-Term Care News guest submissions are the author’s and are not necessarily those of McKnight’s Long-Term Care News or its editors.