Topic 1: Lack of Qualified Workers and Training Capacity – The Coalition’s most recent survey again shows that long-term care providers are struggling to hire and retain direct care workers and nurses. BON’s own data shows that we have fewer CNAs and HHAs today than we had in 2022 and 2023 and that we are not keeping up with increased demand for care. We have also lost capacity to train new Home Health Aides. While we have seen an increase in approved CNA training schools, capacity is not sufficient to meet the growing demand. This leads to two questions:
- What is DC Health doing to expedite and simplify the endorsement process so that providers can hired Maryland and Virginia CNAs and GNAs without undue delay? When can providers expect this process to be effective?
- What, if anything, is the DC government doing to increase capacity to train new home health and certified nurse aides? Is DOH coordinating with OSSE, DOES, the WIC or other agencies to identify workable strategies that can be implemented quickly?
Topic 2 – Allowing CNAs to work in home-based settings. On July 13, 2024, DOH adopted a final rule (17 DCMR 9600.5) that allows a CNA to provide nursing care services in a home setting. The rule requires that a DC registered nurse attest to the CNA’s competency to function in a home care setting. No additional guidance has been published about this rule.
- What must be included in the RN attestation? Is there a required statement? It would be helpful is DOH could issue a form that providers could use so that they have confidence that they are meeting regulatory requirements. Does the attestation need to be filed with or approved by DOH or can an employer simply maintain the record in their HR file?
- Home Support Agency (HSA) rules require HSAs to hire home health aides to work in the home. Under 17 DCMR 9600.5, can HSAs hire CNAs to work in the home provided the CNA has the required RN attestation? HSAs are asking for clarification.
Topic 3 – Certified Medication Aide Training – Rules establishing the MA-C (Certified Medication Aide) credential were finalized in 2019. This credential allows CNAs and HHAs who have completed training and certification to administer medications. The MA-C credential is viewed by employers as very desirable because it helps address the nurse shortage and also offer HHAs and CNAs the ability to increase their skills and pay (which helps with recruitment and retention). In 2023, several training schools applied to get approval to offer training. Earlier this year, we were informed that the problem was the lack of vendor who could administer the test. Can you please update us on the status of the MA-C credential and training schools’ applications? What is causing the delay? When can we expect that a school or schools will be approved and DC CNAs and HHAs will be able to enroll in and complete training and certification for this credential?
Topic 4 – Testing Delays – Training schools report that their students face significant delays between finishing their course work and when they are able to take the skills exam. As a result, students often must take refresher courses; others get discouraged and leave the field completely. What is DC Health doing to eliminate these delays.
Topic 5 – Renewal Process – DC Health has announced that it is adopting a new, staggered renewal process. Effective January 2025, aides will renew their certification based upon their month of birth every two years instead of everyone renewing on the same date. While Coalition members support this change there is concern that no additional guidance has been issues to date. Is DC Health planning to delay implementation and if not, can you share what the process will be and when will guidance be issued? Also, the Coalition previously shared a list of concerns about the complexity of the 2023 renewal process. (See letter to T. Walsh dated October 13, 2023, attached). Has DC Health made any progress to address the concerns raised in our letter?
Topic 6 CNA/HHA Survey – As part of the 2023 renewal process, HHAs and CNAs had to complete a survey. As we detailed in our letter of October 13, 2023, the survey questions were not specific to HHAs and CNAs. Many were confusing and/or difficult to answer. Further, many aides were unable to respond to the survey without help from their employers, raising concerns about the reliability of their answers particularly with respect to questions pertaining to job satisfaction and quality of the work environment. Can you share what DC Health has done to revise the survey questions and process to generate more meaningful data? Will renewing HHAs and CNAs have to complete a survey when the new renewal process goes live? If so, will it be the same survey? Finally, have the results of the 2023 survey been compiled and if so, can you share them with us?
Topic 7 Age for Certification – Council enacted amendments to the HORA that include a provision lowering the age for certification from 18 to 16. Is this provision effective now or must DOH promulgate a rule? If so, when can we expect this rule to be effective? Do you see any obstacles to implementation?
Topic 8 – Scholarships and Training Dollars – Has the High Needs Healthcare Career Scholarship program launched? If so, can you share the present of funding that is supporting training for Home Health Aides and for Certified Nurse Aides? Are any additional scholarship programs being planned?
Topic 9 – Data Needs – To better understand the state of the workforce and whether we are making progress to address the workforce shortage, better data is needed including how to quantify demand and unmet need, how many students are being trained, the capacity of existing schools, numbers of students who take and pass certification exams etc. We also need better data on workforce demographics, tenure and job satisfaction, retention rates, payment rates and whether workers are able to advance their careers and move toward economic stability. We would welcome a discussion about how collectively, the DC government can do a better job of collecting and analyzing data needed to help us identify, sustain and scale successful interventions.