Improving New York's Home Care Aide Training System

Home Care Aide. Training System. #3. New York's Medicaid Redesign is intended to reshape the state's en- tire health delivery system, includ- ing home...

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Improving New York’s Home Care Aide Training System September 2013

New York’s Medicaid Redesign is intended to reshape the state’s entire health delivery system, including home- and community-based services for elders and people with disabilities. The state’s new model will move dramatically away from fee-for-service reimbursement, toward a more efficient and effective “capitated” payment system—one in which a managed-care insurance plan receives a monthly pre-payment to pay for all of an individual’s covered health and social services. This fundamental restructuring is intended to place nearly all Medicaideligible recipients into managedcare plans to coordinate their care needs, and thus better manage their disabilities and chronic diseases— while at the same time, achieving cost efficiencies. PHI Medicaid Redesign WATCH is a three-year project to record, analyze, report—and intervene to mitigate dislocation of consumers and workers—as New York fundamentally transforms its Medicaidfunded long-term services and supports. Funding for this initiative is provided by the Ira W. DeCamp Foundation, the Ford Foundation, the Altman Foundation, and the Bernard F. and Alva B. Gimbel Foundation. Additional partners in this project include Wider Opportunities for Women (WOW) and the National Employment Law Project (NELP).

In 2010, PHI published “Preparing New York’s Home Care Aides for the 21st Century,”1 an analysis of New York’s system for training home care aides. That paper concluded that the state’s home care training system was overgrown and fragmented, leading to variability in quality and system-wide inefficiencies. PHI also found exemplary practices within the New York home care training system, demonstrating that there were plenty of opportunities for improvement. We recommended three actions that the state could take to improve quality: streamline its regulatory structure, consolidate the training into those programs that excel, and define career ladders and other opportunities for advancement. This paper focuses on changes the New York State Department of Health (DOH) has made to the Home Health Aide Training Program requirements since the publication of our 2010 paper. These changes apply only to training programs operated by Licensed Home Care Services Agencies (LHCSAs, which are DOH-licensed providers of home care aide services), and are distinct from those home health aide training programs regulated by the New York State Education Department.2

New York’s Medicaid Redesign is shifting individuals needing long-term care to managed long-term care plans that rely heavily on home care aide services.

Additionally, this paper highlights continuing challenges to building the skilled, stable workforce that will be required as New York’s health care system emphasizes home and community-based over institutional care. Importantly, New York’s Medicaid Redesign is shifting individuals needing long-term care to managed long-term care plans that rely heavily on home care aide services.

Background In December 2010, the New York State Department of Health established a Home Health Aide Training Workgroup, consisting of home care

Medicaid Redesign Watch #3 and hospice providers, association representatives, and DOH staff, to address variability in New York’s employer-sponsored training programs. Their task was to develop a better framework for monitoring—and to improve the quality of—the training programs. The workgroup, which included representatives from PHI, met throughout 2011, and in January 2012, DOH issued an updated Guide to Operation of a Home Health Aide Training Program3 (HHATP), with an effective date of July 1, 2012. In addition to delineating several new requirements, the guide consolidates

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Improving New York’s Home Care Aide Training System • E quipment and Space: DOH recommends approximately 12–20 square feet of space in the classroom and 30 square feet of space in the clinical laboratory setting for each trainee. Specific equipment is also recommended. • Q  uality Assurance: All training programs must have policies and procedures describing their quality management program, including an annual evaluation of the training program. • C  onsolidation of Training Sites: Training programs run by a single company (a provider licensed by DOH) may now consolidate all of their training programs under a single coordinating nurse instructor. By selecting this option, training may still be offered in a variety of sites. However, the coordinating nurse instructor is responsible for the compliance of the sites, and any sites outside of the nurse instructor’s jurisdiction must close. An organization that wishes to continue to operate multiple sites under different nurse instructors is required to have each instructor submit an application to DOH as described above.

The new guidelines establish more stringent requirements for a number of aspects of home health aide training programs. previous DOH requirements and reiterates specific regulations considered essential to effective functioning of a home health aide training program.

New Requirements for Home Health Aide Training Programs The new guidelines establish more stringent requirements for a number of aspects of home health aide training programs but they do not alter the content of the curriculum or the amount of training (a minimum of 75 hours, 59 of which are classroom hours and 16 are Supervised Practical Training) required for certification. The new requirements include the following: • N  urse Instructor Qualifications: Nurse Instructors (RNs) must submit applications to DOH; additional documentation supporting their language fluency is required to train in a foreign language. • T rainee Rights: All trainees must be given a statement of their rights, and a suggested statement is provided by DOH. • T raining and Testing Materials: The regulations require a maximum ratio of 20 trainees to each nurse instructor in the classroom, and a ratio of 10 trainees to one instructor for the Supervised Practical Training (SPT) component.4 All training programs are now required to use a published text that includes the DOH’s curriculum topics and required content, as well as a “bank” of test questions.5

• C  ompetency Testing: Veterans who were trained in the U.S. military as medical technicians or medics are now eligible for competency testing6 without attending a 75-hour training program. The guidelines clarify that if a candidate demonstrates competency in some but not all of the content and skills, the HHATP must provide the appropriate additional training and reevaluate the competency in those areas requiring remediation only. • P  ersonal Care Aide Upgrading: The guidelines clarify that a personal care aide7 (referred to as a Home Attendant in New York City) may be upgraded to home health aide with an additional 35 hours of training that includes 19 hours of classroom and 16 hours of supervised practical training as outlined in the Health Related Tasks Curriculum. In addition, the training program must assure that the personal care aide is competent in the personal care skills and tasks prior to providing additional training. • S  treamlining of Application: New applications for approval and re-approval of training programs have been streamlined to simplify the process.

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Three Subsequent DOH Clarifications

questions is translated with permission from the publisher.

While most training providers view the new guidelines for Home Health Aide Training Programs (HHATPs) as an improvement, the DOH did not originally address three critical issues necessary to stabilizing the aide workforce. These three issues relate to: training in a foreign language; access to eligible Supervised Practical Training (SPT) sites; and clarity as to whether or not the guidelines’ effective date applied to all training programs, regardless of each program’s last approval date.

In the meantime, New York City Council Speaker Christine Quinn, with the support of Councilwoman Maria del Carmen Arroyo, included funding in the City’s Fiscal Year 2013–2014 budget for translating the bank of test questions into several key foreign languages (e.g., Russian, Chinese, Korean, Haitian-Creole and Italian). 2. Limited Number of Supervised Practical Training Sites. Both the previous and new guidelines for an HHATP require that a home health aide have a minimum of 75 hours of training—59 in the classroom and 16 hours of supervised practical training (SPT). Of the 16 hours of SPT, at least 8 hours must occur in a patient care setting that may not be a skilled nursing facility. While HHATPs could use a client’s home for SPT, limited reimbursement precludes this option as it would require sending a nurse into the field with each trainee. Instead, DOH-licensed training programs have traditionally used Adult Day Health programs as the setting in which to complete the SPTs.

1. Limited Availability of Approved Curriculum for Training in a Foreign Language. New York’s ethnic and cultural diversity in both the patient and the aide populations increasingly requires that training be available in multiple foreign languages. HHATPs currently train in a variety of foreign languages (e.g., Spanish, Russian, Mandarin, Cantonese, and Korean). The new guidelines originally required that a textbook be available in the language in which the course is taught. At the time the new regulations went into effect, however, only one foreign-language text, in Spanish, met the new content and testing requirements. Even that text—Providing Home Care: A Textbook for Home Health Aides, 4th Edition (Hartman Publishing, Inc.) —doesn’t fully meet the translation requirement, as the Student Handbook and test questions are translated but not the entire text.8 As yet, no other publishing company has translated their text into a foreign language.

The fairly limited number of sites for SPT training, however, is increasingly inadequate. This is

As many as 25,000 currently employed personal care aides are in need of 35 hours of “upgrade training” to become certified as home health aides by 2014.

In response to the new regulations and their inability to acquire foreign-language texts, some foreign-language training programs stopped training. Others continued to train, arguing that they were still operating under a previous training program approval (see number 3 on next page) and, as such, were legally allowed to continue to train. DOH Clarification: The DOH has since issued a revision to the requirements,9 relieving training programs of the foreign-language textbook requirement. However, the programs must use an approved published textbook (in English). The foreign-language program may test trainees in the language of the course, provided the bank of test

Improving New York’s Home Care Aide Training System

especially true in New York City, where the conversion to managed long-term care10 is accelerating a preference for home health aides over personal care aides. As many as 25,000 currently employed personal care aides are in need of 35 hours of “upgrade training” to become certified as home health aides by 2014. With the increased pressure on training programs to recruit and train more home health aides, including upgrading personal care aides, providers were not finding a sufficient number of adult day programs to meet their SPT needs. The new DOH guidelines, however, were silent on alternative site options.

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Medicaid Redesign Watch #3 DOH Clarification: DOH issued a clarifying administrative letter11 in February 2013 that states that, for certified personal care aides attending an upgrading program, the entire 16 hours of SPT may take place in the skills laboratory of the training program. The clarifying letter to program administrators also notes that a mannequin may not be used for SPT purposes, but that a volunteer may play the role of the client in the laboratory setting. In addition, instructors are required to document that each trainee has demonstrated competency in the skills taught in the laboratory setting. 3. E ffective Date for the Guidelines. The new guidelines became effective February 1, 2012, for all applicants seeking approval for opening a new Home Health Aide Training Program, and July 1, 2012, for existing training programs seeking re-approval.

Improving New York’s Home Care Aide Training System A revised Guide to Operation of a Home Health Aide Training Program has been issued by DOH and is posted on their website.12

Ongoing Challenges Despite the best efforts of New York State, New York City, and home health aide training programs, significant challenges remain with regard to training the future home care aide workforce. These challenges have been exacerbated by the state’s fiscal pressures, the placement of a global cap on Medicaid, and capitated payments to managed-care plans that do not include the full cost of training. Under the

Despite the best efforts of New York State, New York City, and home health aide training programs, significant challenges remain with regard to training the future home care aide workforce.

However, because no text books had been translated into foreign languages other than Spanish, the guidelines’ effective date with respect to training in a foreign language was revised after DOH had an opportunity to assess the situation and devise a solution.

DOH Clarification: The subsequent DOH administrative letter allows existing HHATPs that were granted approval to train in a foreign language prior to July 1, 2012, to continue to train using their previously approved materials until their next re-approval date. However, all other requirements, including the documentation required for certifying a nurse instructor’s fluency, must still be met by July 1, 2012. In order to continue to train in a foreign language, a training program must submit documentation of the approved English text book to be used; formal permission granted by the publisher to translate their materials (e.g., the bank of test questions or learning materials); and documentation of the certified translations of the bank of test questions (mandatory) and instructor materials (if applicable) to the regional DOH office by October 1, 2013. The changes to training in a foreign language will become effective November 1, 2013.

previous system, home care aide training was covered in the fee-for-service rates. Other funding sources that had been add-ons to the fee-for-service rates, such as the Health Workforce Recruitment, Training and Retention funds, have either been absorbed into the managed-care rates or have been withheld when Medicaid spending has approached the cap. The most significant challenges directly affecting the future stability and adequacy of the home care workforce in New York are the following: 1. U  pgrading of Personal Care Aides: The first group of home care beneficiaries to be enrolled in Medicaid managed-care plans were the clients in the Medicaid-funded Personal Care Program in New York City. Although the state’s “Continuity of Care” policy13 allows the client to request that the aide stay with him or her during the transition, there is no requirement that the managed-care plan continue to keep the aide on the case if the client’s condition changes or if the aide’s employer refuses to accept the reimbursement rate offered.14 Moreover, the cost for home health aide services remains less than those for personal care services until 2014, when the

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Medicaid Redesign Watch #3 Home Care Aide Wage Parity law is fully phased in.15 Consequently, during this transition period, it is more financially advantageous for the plans to use home health aides. Though it is clear that it is essential to upgrade tens of thousands of personal care aides, to date there have been very limited funds made available to accomplish this goal: The 1199 SEIU Training and Education Fund (TEF) used a portion of their funds in 2011 to upgrade aides, providing vouchers for aides to use at proprietary training schools (starting with the Homemakers and Housekeepers as their hours were being capped at 8 hours per week). In addition, in early 2013, the New York City Workforce Investment Board and the Department of Small Business Services made a limited amount of funding available for the City University of New York (CUNY) to offer home health aide training and certification through several of its sites. This funding, although helpful, will still leave thousands of home attendants16 dependent either upon employers with HHATPs to hire and upgrade them (even absent dedicated funding to pay for this training), or on proprietary programs for which the aides may have to pay out of pocket.17

home health aide services. Under such significant reimbursement constraints, those agencies that currently train may ultimately have no alternative but to shed costs, either by reducing training hours to the bare minimum required or closing their training programs altogether. No “dedicated” funding streams currently exist to provide entry-level training for the home care aide workforce. Funds from the New York State Health Care Workforce Recruitment, Training and Retention program—allocated on the basis of Medicaid utilization—are provided to managed-care plans and contracting agencies (e.g., Certified Home Health Agencies and hospices) with the expectation that they will share at least some of these dollars with their subcontractors, the LHCSAs, for the purpose of training. However, there is no requirement that these funds be directed toward training—only that they be used to “support” staff who provide direct patient care. At any time, these funds may be directed away from training to other purposes. More importantly, the state, approaching the Medicaid budget cap, did not pay out these funds in fiscal year 2012.

Those agencies that currently train may ultimately have no alternative but to shed costs, either by reducing training hours to the bare minimum required or closing their training programs altogether.

2. F inancing HHATPs: As the majority of the state’s Medicaid beneficiaries move into managed care, there is no distinct mechanism to pay for the entry-level training, upgrading, or advancement opportunities for the home care aide workforce upon which hundreds of thousands of New Yorkers depend to help manage chronic disease and disability. Today, managed-care plans are pre-paid a “capitated” rate for each patient on a monthly basis. The rate is based on past costs trended forward, but does not necessarily recognize the full cost of training (past costs include a mix of payment rates that were averaged in order to arrive at a rate for the Managed Long-Term Care plans).18 As a result, the Licensed Home Care Service Agencies (LHCSAs) that do not train their own aides have a significant competitive cost advantage over LHCSAs that do, when a managed-care plan is contracting for

Workforce Investment Act money may also be used for home health aide training, but is insufficient to cover the upgrading of the entire personal care aide workforce. 3. T raining in a Foreign Language: Despite the generosity of the New York City Council, a significant investment is still needed to translate learning materials for trainees who speak a multitude of languages. It is not clear who should pay for this, as the cost of translating materials is certainly not addressed in the rate paid by the state to the managed-care plans. An equally critical issue is the availability of bilingual trainers who meet the nurse instructor qualifications, particularly since

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Medicaid Redesign Watch #3 the nurse instructor must be an RN with at least two years of experience, one year of which must have been spent in home care. These issues are not limited to the metropolitan New York City area, as growing numbers of residents in upstate New York speak languages other than English. 4. I nability to Judge Current or Future Capacity: As New York transitions from the highly segmented system of multiple home care programs to the managedcare environment, there will be many changes in the utilization of aide services, hours of care, and need for home care aides. The final step to wage parity will increase the cost for aide services at a time when a rise in the state’s minimum wage is also increasing the cost of overtime.19 Consequently, employers will likely avoid overtime by assigning more aides to each case. Though assigning more aides to high-hour cases is not necessarily problematic, it could mean that more aides are employed part-time. That trend is currently being exacerbated by the Affordable Care Act (ACA), which requires employers of 50 or more to provide health insurance to employees who work full-time (at least 30 hours a week). Though this requirement has been delayed until 2015, employers have already begun to reduce hours, forcing aides to find work with two or more employers in order to earn sufficient income. Increased costs may also impact choices that the managed-care plans make—for example, the plans may try to substitute day care and senior centers for aide services in the home. Consequently, until the transition to managed long-term care is complete20 and the system has been operating for at least a year or more, New York has no way of estimating how many aides it will need going forward. Similarly, the state has no idea how many training programs it needs, particularly since it cannot accurately ascertain whether or not it currently has sufficient workforce capacity to meet population needs.

Improving New York’s Home Care Aide Training System who enter a training class, graduate, and are hired, it does not track whether the aide is employed fullor part-time. 5. A  Disconnection from Workforce Development: The majority of the people who enter home health aide training classes are women who have either never been employed or have recently experienced a lengthy period of unemployment.21 These individuals need more than training—they face considerable challenges when it comes to completing the training and transitioning into work placement. Employers, already unable to recoup the costs of training, are unlikely to fund case managers or provide the kinds of services that help trainees succeed—for example, access to day care, transitional money for transportation, and uniforms. These services are available through Workforce1 Career Centers, where case managers with expertise in health care employment assist unemployed women to find jobs. But these centers often lack data on which training programs have the best outcomes, such as sustained full-time employment and opportunities for advancement. As a result, they may direct clients to training programs with poor long-term outcomes. 6. M  ultiple Regulating Agencies: New York State’s home health aide training programs can be found in a variety of settings: employer-based training programs, community colleges, Boards of Cooperative Educational Services (BOCES), high schools and proprietary training schools. As PHI has documented previously, the employer-based programs are licensed by DOH and the remaining

Importantly, having too many aides can be just as problematic as too few, for when there is excess capacity, aides do not get full-time work.

Importantly, having too many aides can be just as problematic as too few, for when there is excess capacity, aides do not get full-time work, leaving them with insufficient income to support themselves and their families. While the New York State Home Care Registry tracks the number of aides

programs are licensed by the New York State Education Department (SED). The DOH-licensed programs may charge students only a limited fee,22 but those licensed by SED may charge hundreds of dollars in tuition. Additionally, the approval processes, training requirements, and the sites used for SPTs differ.

Medicaid Redesign Watch #3 To make licensing issues more complex, three different departments within SED have authority to approve training programs, depending upon the site at which the program is offered. This complexity is detrimental to the low-income individuals who need training and employment but

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Improving New York’s Home Care Aide Training System and conditions, developing appropriate curricula to address these topics, and increasing the number of required training hours to incorporate the new material. Just as it is critical for New York to develop a more robust quality improvement program for long-term supports and services, it needs to develop measures that assess the quality of the training and preparation for the home care workforce. Given the need to identify a distinct funding stream for training within the context of constrained public budgets, now would be a good time for New York to set about strengthening, consolidating, and streamlining the training system by funding only those programs that provide high-quality training directly linked to employment.23

The state has done little to harmonize the training requirments across regulatory agencies. may not know how to choose a training program. Unfortunately, neither regulatory agency tracks the workforce outcomes (e.g., rates of completion, type of employment after training), and the state has done little to harmonize the training requirements across regulatory agencies. 7. A  ssessing Quality: To improve New York’s home care programs, consistent data that allows for comparisons across programs must be collected and reported. Unfortunately there is no consistent set of quality indicators being used for this purpose. The DOH requires HHATPs to record test scores, trainee competency with respect to skills and tasks taught, and graduation rates. HHATPs are also required to evaluate the quality of their training programs on an annual basis. Since the training programs collect this data themselves— and much of it is subjective in nature—it cannot be used effectively to compare outcomes across programs. Moreover, this data does not answer key questions regarding employment and care quality. Training programs collect little or no data regarding trainee satisfaction or employment retention rates. Nor are there industry-wide surveys that would allow for comparative assessments of each program’s training and employment practices and the quality of care delivered by its graduates. Finally, the minimum training requirement for home health aides—75 hours—is insufficient for the workforce needed in the coming decades. Recognizing the growing number of clients with multiple chronic diseases and disabilities, the preparation of home health aides should be strengthened by identifying competencies necessary to care for individuals with prevalent diseases

Conclusion New York’s home care aide workforce is large and projected to grow in the coming years: In New York City, home care aides—numbering over 150,000— comprise one the largest single occupational groups. One out of every seven low-wage workers in New York City is a home care aide. New York’s aging demographic will only compound the need for a well-trained, stable home care aide workforce, particularly with state health policy relying on delivery of home and community-based care. Yet despite recent efforts to improve the training programs, many issues remain to be addressed. Training of the home care workforce of the future must become a priority for policymakers, consumers, and managed-care plans, which are increasingly playing a dominant role in the choices that affect New Yorkers. Since our 2010 study, PHI has continued to participate in efforts to clarify and improve the requirements for home care aide training. As we chronicle in this paper, the New York State Department of Health has continued to refine the requirements for training programs, instituting more stringent rules regarding the qualifications of instructors, the type of classroom equipment, and the rights of trainees. Allowing for the streamlining of programs under a single approved nurse instructor also has been helpful. However, many of the changes necessary to address the challenges outlined above are outside

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Improving New York’s Home Care Aide Training System

of the scope of the DOH Bureau of Home and Community Based Services, which has authority for the home health aide training program.

requirements remain an impediment to New York State creating a streamlined home care service system providing consistent quality outcomes.

First, the state’s transition from a fee-for-service payment environment to capitation has largely ignored the costs of training, which has left

Recommendations In light of the above conclusions, PHI recommends that New York State take the following actions:

The state’s transition from a fee-for-service payment environment to capitation has largely ignored the costs of training. many LHCSAs wondering how they are going to continue to pay to train their workers. When training programs are questioning their continued financial viability, it is difficult to focus on improving outcomes. Second, given the policy goals of the state—to better coordinate and manage care for those who suffer from chronic illness and disabilities—and the acuity of the population being served at home and in the community, 75 hours of training is clearly insufficient for an aide to fully gain the knowledge and expertise necessary to provide high-quality services. Moreover, with the shift to care management teams, every training program should better orient aides to the new environment, which now includes care managers, nurses, and social workers employed by managed-care companies. This too is additional content that cannot be squeezed into the current 75-hour minimum requirement. Third, the state still lacks sufficient data to guide policy making. New York does not know if it has a sufficient number of training programs—or if those programs provide the necessary capacity to train aides in languages other than English. In addition, PHI’s experience suggests that it is difficult to recruit nurse instructors who can meet the requirements for approval. And despite the DOH’s latest efforts to improve the quality of the training programs, we have few indicators as to which programs have better outcomes in terms of the aides’ overall skills, confidence, and ability to sustain employment over time. Finally, there remain two distinct regulatory agencies with oversight for the home care aide training programs—the Department of Health and the State Education Department—whose differing

1. C  reate a dedicated funding stream for home care aide training—to ensure that essential entry-level and specialized training investments are not squeezed out of the cost structure of even high-road LHCSA employers.

2. Align Department of Health and the State Education Department requirements and curricula for Home Health Aide Training Programs. Require both departments to regularly assess and address the differences in their requirements in order to unify the training for home health aides. 3. Publish tuition rates and performance indicators for proprietary training programs regulated by the State Education Department. 4. Create a statewide measurement tool to capture essential indicators from training programs such as enrollment, completion rates, employment rates, and retention at varying points of time. 5. Develop a current database of HHA Training Programs that indicates performance level and share this information with the Workforce1 Career Centers. 6. Fund pilots that connect employers directly with case managers, either by employing case managers full-time or working directly with the Workforce1 Career Centers. 7. E stablish a sub-cabinet of workforce and training specialists among the departments of Health, Labor, and Education and the offices of Mental Health, People with Developmental Disabilities, and Alcohol and Substance Abuse—to identify the core competencies needed by direct-care workers in each, and to articulate how a worker might easily transition from one field to the other. 8. U  ndertake efforts within the health care sector to identify the potential career paths and new occupations for aides wishing to advance, beginning with a Medication Aide or Advanced Aide pilot.

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Endnotes 1 “Preparing New York’s Home Care Aides for the 21st Century: Overcoming Fragmentation, Inadequate Training, and Limited Quality Control,” is available at: http://phinational.org/sites/phinational.org/files/clearinghouse/PHI-483%20NY%20Training.pdf 2 The regulatory responsibility for the home care aide training system in New York State is shared by the New York State Department of Health (DOH) and the State Education Department (SED). The DOH regulates the aide training programs operated by providers— primarily Licensed Home Care Services Agencies (LHCSAs)—and SED licenses training programs that are operated by educational organizations such as community colleges as well as proprietary schools. The two agencies’ requirements are similar but not identical. 3 The New York State Department of Health’s “Guide to Operation of a Home Health Aide Training Program” is available at: http://www.health.ny.gov/professionals/home_care/docs/hhatp_guide.pdf 4 Supervised Practical Training is the 16-hour component of the training that involves the demonstration of skills. Eight hours may be completed in a lab setting that is part of the classroom, but the final 8 hours must be completed in a home-like setting such as an Adult Day Health Program. A DOH-licensed training program may not use a nursing home for these final 8 hours. 5 When the guidelines were issued, the only text book with a bank of test questions that follows the DOH Curriculum outline was published by Hartman Publishing, Inc. 6 Others who may take a competency exam without attending a 75-hour training include: a nursing assistant with one year of full-time experience within a general hospital within the past five years; an individual with documented home health aide or nurse aide training and competency evaluation from an out-of-state training program; a home health aide with documented home health aide training and competency evaluation who has not been employed as a home health aide for 24 consecutive months; and a nursing student who has documented evidence of successful completion within the past 24 months of course work requiring mastery of home health aide tasks. 7 A personal care aide (PCA) receives a minimum of 40 hours of training and receives 6 hours of in-service training annually. PCAs can perform housekeeping and personal care tasks (e.g., bathing, grooming, dressing, toileting) to assist the patient or client. A home health aide receives a minimum of 75 hours of training and 12 hours of in-service training annually. In addition to housekeeping and personal care tasks, the home health aide can perform medically related tasks such as taking vital signs or dry dressing changes. 8 Hartman has indicated that they do not intend at this time to translate the text into Spanish; DOH however says that there may be another text approved shortly. 9  http://www.leadingageny.org/linkservid/7BC6E8C9-053C-7A1B-F472E402B817050D/showMeta/0/ 10 For a description of the conversion of New York State’s Medicaid fee-for-service system to that of managed care, go to PHI’s New York page: www.phinational.org/newyork 11 NYS Department of Health “Dear Administrator Letter” (DAL), “Clarification of DAL HCBS 12-01 and Revisions to HHATP Supervised Practical Training Requirements: HCBS 13-03, February 19, 2013” are addressed in the replacement to the Guide to Operation of a Home Health Aide Training Program, Revision dated July 1, 2013 at: http://www.nyscal.org/files/2013/07/071713-DHCBS13-14-Guide-to-Operation-of-a-HHA-Training-Program-Revision-date-070113.pdf 12 http://www.nyscal.org/files/2013/07/071713-DHCBS-13-14-Guide-to-Operation-of-a-HHA-Training-Program-Revision-date-070113.pdf 13 The “Continuity of Care” policy is contained in legislation enacting the movement of Medicaid clients into managed care and is found at: http://www.health.ny.gov/health_care/medicaid/redesign/docs/2012_04_26_continuing_of_care_policy.pdf 14 The DOH “Continuity of Care” policy requires the plans to pay the “posted Human Resources Administration (HRA) rate” until December 31, 2013; however, if the provider of services cannot meet the plans’ contractual requirements or refuses to accept the posted rate, the plan is not required to contract with that provider. 15 See PHI’s Medicaid Redesign Watch #1,”Wage Parity for Home Care Aides“ at: http://phinational.org/policy/state-activities/ phi-new-york/medicaid-redesign-watch 16 Faith Wiggins, Director of Home Care Training and Grants for 1199 SEIU Training and Education Fund, estimates that 65 percent of the 13,292 home attendants who have expressed interest in upgrading have not been served as of July 9, 2013. 17 The cost for training at a proprietary school can be $600 or more if paid by the individual seeking certification.

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18 See PHI’s Medicaid Redesign Watch #2, “The Impending Threat to the NYC Home Care System,” April 2013, at: http://phinational.org/policy/state-activities/phi-new-york/medicaid-redesign-watch 19 New York’s minimum wage will increase to $8.00 an hour on January 1, 2014, making the overtime rate $12.00 an hour. 20 The clients currently in home care will transition throughout 2014, but there will continue to be other populations, such as nursing home residents and those living in counties with later transition dates, transitioning during 2015. 21 2012 data from PHI’s affiliate, Cooperative Home Care Associates, indicates that 76% were unemployed and 18% had never been employed. 22 DOH-licensed training programs may charge a trainee up to $100 to recoup the cost of training materials, supplies, or equipment. 23 The UJA-Federation’s Caring Commission, the Harry and Jeanette Weinberg, New York Alliance for Careers in Healthcare, the New York Community Trust, and the Tiger and Surdna Foundations are funding a Homecare Aide Workforce Intervention that is testing and evaluating employment and training practices in four home care companies. The curriculum is 120 hours. The adult learner-centered training uses the knowledge and skills of the learners to increase their self-confidence and skill.

PHI (www.PHInational.org) works to transform eldercare and disability services. We foster dignity, respect, and independence —for all who receive care, and all who provide it. The nation’s leading authority on the direct-care workforce, PHI promotes quality direct-care jobs as the foundation for quality care. To learn more about PHI’s Medicaid Redesign Watch, visit www.PHInational.org/newyork or contact PHI New York Policy Director Carol Rodat at [email protected] or 402-718-7226. For timely alerts on New York long-term services and supports and workforce policies, create an account at www.PHInational.org/subscribe. National Headquarters: 400 East Fordham Rd, 11th floor • Bronx, New York 10458 • Phone: 718.402.7766 • E-mail: [email protected] © Paraprofessional Healthcare Institute, September 2013