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.