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How can I be sure that my unlicensed staff or home health aides meet the competency criteria?

Wednesday, November 1, 2017   (0 Comments)
Posted by: Mandy Rubenstein
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The excerpt below is taken from the frequently asked questions to the Minnesota Department of Health (MDH): “Does an unlicensed staff person who is on the nursing assistant registry need to be competency tested by the home care RN on the training/competency requirements in Minnesota Statutes, section 144A.4795, subdivision 7, (b) and (c)?

Staff who meet the requirements at Minnesota Statutes, section 144A.4795, subdivision 3 (b) (2) “satisfy the current requirements of Medicare for training or competency of home health aides or nursing assistants, as provided by Code of Federal Regulations, title 42, section 483 or 484.36” do not need to be competency tested by the home care RN on the training/competency requirements in Minnesota Statutes, section 144A.4795, Subdivision 7 (b) and (c).

Please note subdivision 4, Delegation of home care tasks. “A registered nurse or licensed health professional may delegate tasks only to staff who are competent and possess the knowledge and skills consistent with the complexity of the tasks and according to the appropriate Minnesota practice act.” This indicates that even for staff who meet the requirements at 144A.4795 Subdivision 3 (b) (2), the registered nurse or other health professional would need to ensure appropriate delegation of tasks to meet the client’s individual needs and preferences. (11/19/14)”


For a competency evaluation of unlicensed staff in a comprehensive licensed only home health agency in Minnesota, the required content according to 144A.4795 includes the following:
• Documentation requirements
• Reports of changes in the client’s condition
• Basic infection control
• Maintenance of a clean and safe environment
• Appropriate and safe techniques in personal hygiene and grooming
    o Hair care and bathing
    o Care of teeth, gums and oral prosthetic devices
    o Care and use of hearing aids
    o Dressing and assisting with toileting
• Training on the prevention of falls
• Standby assistance techniques
• Medication, exercise and treatment reminders
• Basic nutrition, meal preparation, food safety and assistance with eating
• Preparation of modified diets as ordered by a licensed health professional
• Communication skills, including preserving the dignity of the client and showing respect for preferences, cultural background and family
• Awareness of confidentiality and privacy
• Understanding appropriate boundaries
• Handling emergency situations
• Awareness of commonly used health technology equipment and assistive devices
• Observing, reporting and documenting client status
• Basic knowledge of body functioning and changes in body functioning, injuries or other observed changes
• Reading and recording temperature, pulse and respirations
• Recognizing physical, emotional, cognitive and developmental needs of the client
• Safe transfer techniques and ambulation
• Range of motion and positioning

If an unlicensed staff member has not regularly performed the delegated task for a period of 24 consecutive months, he or she must demonstrate competency in it to the RN or licensed health professional.

Under current Medicare Conditions of Participation G213, 484.36(b)(2), (as of 11/1/2017), the required content of the competency evaluation for Medicare certified agencies must address the following.
• Communication skills
• Observation, reporting and documentation of patient status and the care or service furnished
• Reading and recording temperature, pulse and respiration
• Basic infection control procedures
• Basic elements of body functioning and changes in body function that must be reported to an aide’s supervisor
• Maintenance of a clean, safe and healthy environment
• Recognizing emergencies and knowledge of emergency procedures
• The physical, emotional and developmental needs of and ways to work with the population served, including the need for respect for the patient, his/her privacy and his/her property
• Appropriate and safe techniques in personal hygiene and grooming
    o Bed bath
    o Sponge, tub or shower bath
    o Shampoo, sink, tub or bed
    o Nail and skin care
    o Oral hygiene
    o Toileting and elimination
    o Safe transfer techniques and ambulation
    o Normal range of positioning
    o Adequate nutrition and fluid intake

If the RN or other licensed health professional regularly delegates tasks outside of those listed above (e.g. blood pressure, blood glucose monitoring, medication administration), the agency may choose to conduct a competency evaluation of the task for all unlicensed staff upon hire. The RN or other licensed health professional is still responsible to assure that the unlicensed staff member is competent in the task for each client/situation for which the task is assigned.

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