DOH Guidance Addresses Aide In-Service Training Requirements  

Situation Report | January 25, 2021  

The state Department of Health (DOH) has issued guidance to address the in-service training requirements for personal care aides (PCAs) and home health aides (HHAs) during the COVID-19 pandemic.  

PCA In-Service 

As a follow up to its October 13, 2020 guidance, DOH is extending its “enforcement discretion” for surveys involving PCA in-service training requirements (3 hours on a semiannual basis) that are due through June 30, 2021. (The prior guidance announced “enforcement discretion” for PCA in-service education that was due between January and June 2020.)  

HHA In-Service 

Following up on the October 13, 2020 guidance, DOH is also continuing its policy to exercise enforcement discretion when assessing agencies for completion of HHA annual in-service training (12 hours annually) until the sooner of: the end of the first full quarter following the end of the Public Health Emergency by the U.S. Centers for Medicare and Medicaid Services or expiration of Executive Order No. 202.  

Still, DOH strongly encourages employers to complete the in-service requirements for HHAs and PCAs as soon as is practicable and to document such training in staff personnel files.  

HCA advises members to document any barriers to timely completing the in-service trainings and actions taken to address those obstacles.  

DOH also reminds employers that in-services for PCAs and HHAs can be conducted remotely or through other off-site methods such as online education. All in-service education should be done under the supervision of an RN with an opportunity for questions to be answered and should be accompanied by validation that learning occurred. Regardless of the method selected for completion of the in-service, the agency must document that the in-service was completed in each aide’s personnel files.  

Questions related to COVID-19 should be addressed to; other questions should be addressed to  

HCA has urged — and will continue to advocate — that the annual aide in-service training requirement be waived, as “enforcement discretion” does not provide the necessary protections during the pandemic.