DAL: HCBS 12-01 - Operation of a Home Health Aide Training Program

DAL: HCBS 12-01

Subject: Operation of a Home Health Aide Training Program

Dear Administrator:

The purpose of this letter is to advise home care agencies and hospices of revisions to the Guide to Operation of a Home Health Aide Training Program that will become effective for all Home Health Aide Training Programs (HHATPs) July 1, 2012. These requirements supersede previous guidelines issued by the Department. The Guide can be accessed on the Department of Health's website and the Health Commerce System.

Background

The New York State Department of Health established requirements for the approval and re-approval of HHATPs on August 19, 1992. These requirements are based on federal regulations found in the CMS Conditions of Participation (CoPs) for Home Health Agencies (42 CFR 484.36) and the CoPs for Hospices (42 CFR 418.76).

In 2009, the Home Care Registry (HCR) was created to defer fraud in training programs and certification and to provide the public a registry on which they could look up individuals to determine if they were, in fact, trained and if they are employable. The development and implementation of the HCR provided an accessible database that includes all home health and personal care aides who were employed on September 25, 2009 and after. Additionally, it provides information on all training programs, their dates of operation and all classes and trainees enrolled since September 25, 2009.

In December 2010, a workgroup consisting of representatives from HHATPs, home care and hospice providers, provider association representatives and Department staff, was convened to clarify requirements, address potential inconsistencies and provide a framework for adequate monitoring of HHATPs. The workgroup's efforts have resulted in the revision of the Guide to Operation of a Home Health Aide Training Program. The members of this workgroup are identified on the acknowledgment page of the Guide, and the Department is appreciative of their contributions.

Major Revisions to the Requirements for Operating a Home Health Aide Training Program

A summary of all revisions to the Guide to Operation of a Home Health Aide Training Program are highlighted below:

Application Guidelines

  • The applications for initial approval and re-approval have been revised and streamlined.

Sites

  • HHATPs approved by the NYSDOH, must be operated by a home care agency approved under Article 36 of Public Health Law or a hospice approved under Article 40 of Public Health Law. Each training program must be operated by a designated licensed or certified entity. Training programs will no longer be associated with a specific site, but rather with a designated sponsoring home care agency or hospice. An approved training program can operate multiple sites where training is conducted continually or episodically.
  • Home care agencies that are currently operating multiple training programs (sites) may choose to operate a single approved HHATP that offers training at various sites under the direction of a Coordinating Nurse Instructor. Agencies choosing to implement this option must identify which currently approved HHATP(s) will close and the effective closure date for each. The identified program will be closed on the Home Care Registry (HCR). The closure date should be the date of the last training conducted by the program at that site. The home care agency must utilize the HHATP Address Verification Form, Attachment A to this letter, to communicate this information to hhatp@health.state.ny.us.
  • The training program must designate at least one approved Nurse Instructor to be responsible for the coordination of training activities and oversight to ensure that training and supervision of practical training is consistent across sites. This designated Nurse Instructor(s) must be listed on the HHATP application as the Coordinating Nurse Instructor(s).
  • All training sites must meet minimum location, equipment and space requirements as specified in the Guide.

Trainee Rights

  • Trainees must receive written documentation of their rights as a trainee that meets minimum criteria specified in the Guide.

Nurse Instructor

  • A Nurse Instructor application must be submitted to the Department with the instructor's signature. Additional supportive documentation is required if the instructor proposes to train in a language other than English.
  • All training must take place under the direction of an approved Nurse Instructor(s).
  • All supervisors of practical training must be approved Nurse Instructors listed in the HCR.

Training and Testing Materials

  • The training program must be conducted utilizing lesson plans based on content of the Department's Home Care Curriculum (HCC) and Health Related Tasks Curriculum (HRTC) available on the DOH website and Health Commerce System.
  • All training programs are required to use a published text consistent with the content of the Department's HCC and HRTC curriculum. The training program is responsible to evaluate and ensure each trainee is competent in the training material by utilizing written tests obtained from publishers who publish text books for the purpose of training home health aides. Test questions must be obtained from a "bank" of test questions. Trainee evaluation forms must be used to document competency of required skills.
  • All training programs are required to provide the trainee with a copy of their completed Home Health Aide Trainee Evaluation Forms found in Appendix 5 and 5A of the Guide.
  • The Trainer and Trainee Manuals developed in 1992 by the State University College of Buffalo under contract with the State Department of Social Services should not be used and will no longer be made available.

Foreign Language

  • A training program will only be approved to conduct training in a foreign language if the approved Nurse Instructor meets the specified proficiency requirements in the foreign language. Additionally, the use of published textbook(s) and associated written tests in that language are required, meeting the specifications as described above.

Quality Assurance/Quality Improvement

  • The training program must actively participate in the sponsoring home care agency or hospice's quality management program. This participation will include quality assessment and improvement activities conducted on a quarterly basis as well as a written annual evaluation of the training program. Programs may choose to utilize tools developed by the Department and provider workgroup which are found in Attachments 3A, 3B and 3C of the Guide. The use of these tools is optional.

Implementation

Effective February 1, 2012, all applicants seeking initial approval as a Home Health Aide Training Program must meet the requirements in the revised Guide. Effective July 1, 2012, all existing HHATPs seeking re-approval must comply with the requirements described in the revised Guide. Consideration will be given to HHATPs seeking re-approval that have existing leases (in effect prior to February 1, 2012) for meeting the space requirements.

For questions or clarification on this directive, contact the New York State Department of Health, Division of Home and Community Based Services at hhatp@health.state.ny.us.

Sincerely,

Rebecca Fuller Gray
Director
Division of Home & Community Based Services

Attachment A

HHTAP Training Materials