1) Amend 18VAC90-26-10, 90-26-20, and 90-26-50 to allow nurse aide training to occur outside of a nursing home facility focusing on geriatric care; 2) amend 18VAC90-26-30 to remove requirements for geriatric care experience for RN and LPN instructors, and to allow instructional personnel from other health professions to supplement the primary instructor 

Regarding Amendment 1 and part of Amendment 2:  Not all long-term care populations are geriatric.  Conversely, nearly every hospital experience will involve some geriatric care.  Certified nurse aides are employed by hospitals, schools, prisons, nursing homes, et al.  It's time that their training reflected this.  

I support the proposed changes with the exception of 18VAC90-26-20 B.2. Requiring training programs not to charge a fee puts an undue financial burden on training centers that are not allocated/reimbursed training dollars. This will cause training centers to not admit employed students, further impacting the new CNA workforce. Nursing facilities are able to use CMS allocations for staff training but Career and Technical Education Centers such as High schools, Colleges, etc., do not receive these funds. The proposal should, at a minimum, not remove the word "nursing" from the employment definition as there is no alternative definition for "Facility" in the definitions list and it may cause confusion.

Additionally, I feel the state should have a way for NA students (or the training centers) to apply for training reimbursement rather than simply requiring non-nursing facility training centers to simply train without charging for the services and materials.

"Impose no fee for any portion of the program, including any fees for textbooks or other required course materials,  nurse aide student who, on the date on which the student begins the program, is either employed or has an offer of employment from a nursing facility.

I noticed the 2 year working requirement for teachers being reduced to 1 year of working experience. My concern is that the SCHEV regulations require teachers to posses 2 years of working experience to be considered qualified to teach. There appears to be a disconnect between the two regulations. SCHEV requirements will still need to be met by schools in Virginia, making this specific regulation a non-factor.

I am a HR Manager in a skilled nursing facility, to get the facilities out of this shortage each facility should be licensed to have classes in their facility and send them to the boards instead of going thru outside sources. I think the instructor should be a seasoned CNA.

Are these proposed regulatory changes applicable only to the Fast-Track program or would they also apply to a for profit, private owned training center?

The CNA/LPN program needs to be abolished. Some of the worst healthcare provided is from LPN/CNA's. Sorry, not sorry. Whatever is being taught in the program needs to cease. Apply this language to the RN program and get these people trained up to a respectable standard. Also if you want to fix the skilled care facility staffing shortage, start paying people what they are worth. Just about every SNIF is charging obscene fees for care, lining the pockets of administrators while paying the works a starvation wage. 

Having experienced the issue of nurse shortages from a family caregiver perspective,  I write to request the state maintain high standards for both nurse educators and training times with supervision.

The term Quiet heroes can be accurate but only when experienced RNs and LPNs pass their knowledge and tips with in person supervision. MMy father in law required LPN and CNA support at home and the nurses, for thright most were flexible, kind, patient and informed about medical issues. The best had completed two years of training and had worked in a facility prior to doing home care. 

I definitely credit the best educated nurses to th the longest in hospital or nursing home work. The quality of the training our nurses receive will have the greatest impact on the health care provided- numbers of people is only a small part of the solution. 

And the educational centers can't be expected to go unreimbursed. Neither the training nor the materials are without value. 

We thank the Virginia Board of Nursing (BON) for considering actions to alleviate unnecessary burdens on Virginia’s caregiving workforce and to open additional pathways of training for those caregiving individuals employed by licensed assisted living facilities. 

We appreciated the Commonwealth creating a waiver during the early period of the COVID-19 pandemic that removed the restriction on training locations for the clinical hours training of certified nursing assistants (CNAs) to be done outside of a “geriatric long-term care facility,” which included having the hours completed within an ALF. This waiver allowed for assisted living communities to train additional CNAs to help with providing continued resident care with permanent staff members. Having spoken with numerous assisted living providers and with staff from several of Virginia’s regulatory agencies, we support the BON making this waiver a permanent option that would allow assisted living facilities to be included in the allowable training facilities for CNAs. 

I strongly support these changes.  As an organization that supports 27 communities in Virginia, we need to be able to bring more people into our industry.  We would welcome the opportunity to be able to train candidates in our own environment, vs skilled care, and we want to be part of the solution to the staffing challenges in the senior living industry.  Thank you!

I strongly support the changes being put forth for amending the CNA Program to include Assisted Living Facilities as a clinical site. It will help with CNA advancement into further healthcare positions, it will aide in staffing shortages seen across ALF's statewide, it will benefit residents' care within our communities and it will increase the CNA knowledge base of where they are able to practice upon completion of their state exam. Thank you for the opportunity to be included and bringing additional attention to ALF's across Virginia.

This initiative can be a pivotal point for the Assisted Living sector of healthcare by giving us the ability to thoroughly train and support CNAs through investing in them-so they in turn invest in our resident's quality and continuity of care. It is important to note that CNAs are needed across the Commonwealth in a multitude of different roles and sectors, even those outside of the normal "healthcare" realm. We are talking about empowering and providing training for Virginians interested in a servant career who may otherwise not have the means to get the training elsewhere. If folks WANT to care for our aging population, WHY wouldn't we find a way to help this happen for them? If we are all open to change, then it shows we are invested in being part of the solution. It takes hard work, dedication and commitment from organizations such as mine to make this successful, but it's much more likely to yield successful results than not, which is why it's worth the fight!

Support!!

We have several communities in Virginia and with the current staffing crisis, we need to be able to train our own people in our setting. 

As an HR professional in the senior living space, I strongly support the proposed changes to allow more VA residents to obtain their CNA training through alternative previously unavailable methods. As an employer, we have a critical interest in addressing staffing and skills. We can produce passionate employees who care about their work and the people they serve. We can also provide career growth and a stable industry where people can thrive!

Thank you for this open-minded, long-term solution, to assist in the full employment of Virginians and caring support for our residents.

As an HR professional trying to recruit, train and retain team members in our Virginia assisted living communities, I fully support this change. Being able to train our own associates in an assisted living environment given the fight for talent would be huge. 

I support any change to CNA training that loosens the restrictions and helps with our staffing crisis.

While we as caregivers can all benefit from experience in providing care to geriatric patients, the vast majority of healthcare organizations include them in their populations served.  This provides the opportunity to train staff in a variety of settings allowing them to use their training and skills to advance in Nursing or other healthcare related field.  I do share some concerns related to the one year of experience, all of us as caregivers are teachers and I hope that we will see more instructors passionate about the role and their students successes.    

I fully support the allowance for nurse aid training within the assisted living facility.  We need all avenues to support career paths in healthcare and help combat staffing shortages.  

I fully support the allowance for nurse aid training within the assisted living facility.  We need all avenues to support career paths in healthcare and help combat staffing shortages.  

CNAs work in all areas and this will help them and train and prepare accordingly. 

To allow nurse aide training to occur outside of a nursing home facility focusing on geriatric care. 

We struggle to place nurse aide students in a nursing home facility only, given the restrictions that have been in place. We agree and support the proposed change that should include assisted living as a clinical site. This is much less disruptive to a nursing student and nursing program.

To update requirements of the coordinator and instructional staff.

We are in agreement that the RN/LPN instructor may have 1 year of experience vs. 2 years of experience outside of the geriatric setting.

Only the Program Coordinator or the Primary instructor is required to hold a license as a registered nurse.

We agree this eases the financial burden for any nursing assistant school. With the involvement of the RN coordinator, perhaps it is possible to have additional oversite responsibilities of the RN coordinator to ensure the non-RN instructor is successful in meeting all requirements of the program. 

I fully support the allowance for nurse aid training within senior living communities.  We need all avenues to support career paths in healthcare and help challenge staffing shortages. This will make it easier for all providers to better care for our senior population. 

We need to explore all avenues possible to provide the quality workforce we will need in the not-too-distant future.  Our CNA students need exposure to a wider variety of work-based learning environments.  We appreciate being able to assist our geriatric population but there is so much more that these students need to be exposed to and be familiar with.  Please consider lifting restrictions on age requirements.  Create incentives for the healthcare industry that will encourage them to become involved in these programs as well.

As both an employer and leader in senior living, I strongly support the proposed changes to allow prospective CNA's to obtain their training through alternative and currently unavailable settings. Having completed training as a CNA years ago, I have a heightened awareness of their obligations that will help address the skills needed and ultimately result in improved staffing in our industry.   

Thank you for your consideration of this much needed solution. Ultimately, your decision will help provide quality care for the many residents across the Commonwealth.

I work in the public school system. The last 2 years we had a Nurse Aide program but the instructor went to a new school district. We had tried to find a new instructor with absolutely no interest. I was asked to step-up and take over. Unfortunately the geriatric requirement prevented me from being approved. I have been a nurse for almost 11 years. I have geriatric experience as an LPN but since I obtained my RN my experience is pediatrics. We desperately need more people in the medical field and I would be honored to assist in that. I fully support the changes requested so more programs can open up. 

Request to Amend 18VAC90-26-20. Establishing and maintaining a nurse aide education program

B.2. Impose no fee for any portion of the program on any nurse aide student who, on the date on which the student begins the program, is either employed or has an offer of employment from a nursing facility.

• This Administrative Code implies that tuition is free for anyone working in a nursing home in any capacity. 
• Are colleges and schools to verify employment prior to enrollment? How does that process work?
• How do colleges and programs get tuition reimbursed if we find out they are employed at a nursing facility and didn’t disclose?

There are many personal interpretations of the code to include “this only applies to Nursing Facilities that have an education program”. Which may be the case, but it is not written as such.  Further clarification and definition are needed on the code so all programs can maintain their status of being in good standing with the BON.