I think it is fine to require that all direct care have basic first aid however, I do not think it is necessary for all direct care to have CPR.  A  Center should have enough qualified people on staff  (2 on the floor, for example), who can perform cpr until emergency help arrives.  However, there may be very qualified staff who provide direct client care who are unable to perform CPR. This reguation would prevent them from eligibility as direct care staff.  In adult day health care, it is safe to say that almost all staff provide direct care at some point.  In large facilities, this is an expense both for cost of training and time out for training.