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DOH Issues DAL: DHCBS 20-09 regarding PCA and HHA Virtual Hybrid Training Approval Process

Late on Tuesday, September 29, the Department of Health (DOH/the Department) issued DAL: DHCBS 20-09 regarding Personal Care Aide and Home Health Aide Training Program Hybrid Training Approval Process. 

This DAL was issued in response to HCP’s remote PCA and HHA training proposal that was jointly submitted to DOH by HCP, HCA and Leading AgeNY (the Associations). This DAL is for Personal Care Aide Training Programs (PCATPs) and Home Health Aide Training Programs (HHATPs) which currently have approval to provide training through DOH and whose training programs have received at least one re-approval after a period of three years.

As was described in the Associations’ proposal, the COVID-19 crisis required training programs to cancel, suspend or postpone scheduled or in-progress training classes. 
The DAL allows and provides guidance to assist training agencies to develop a hybrid model of online training for PCAs and HHAs.

The DAL provides the requirements and the information needed to approve a hybrid model of online training and does not replace any current criteria for training. DOH emphasized that all other criteria for in-person training remains in place. 

Providers wishing to provide PCA and HHA training pursuant to this DAL must receive DOH approval to do so by submitting to the Department the information outlined in the DAL. 

Failure to do so upon initial submission may result in a delay in processing the request or a denial of approval.

The following agency information is required with your request for approval.

Agency Demographics Form:

One Agency Demographics Form is required for each license number (DAL Attachment 1): 
1. Agency Name;
2. Agency Address;
3. Agency License Number;
4. Training Program Approval Type;
5. Address where testing, skills, and Supervised Practical Training (SPT) will be
6. Language(s) – Please note that prior Foreign Language approval is required;
7. Name of Nurse Instructors Responsible for Hybrid Training;

Attestations: The following are Operator/Administrator attestations required for Hybrid Training approval. 

If your agency is requesting Hybrid Training approval for both PCA training and HHA training, both attestations are required:

1. PCATP Attestation (PCATPs Only, DAL Attachment 2);
2. HHATP Attestation (HHATPs Only, DAL Attachment 3);

Hybrid Training Program Schedule (DAL Attachment 4): 

The schedule must include the content of the training program modules/units (didactic portion of training) and administration of written and (required and optional) skills performance evaluation. 

The schedule must indicate if the session being held is online or in the skills laboratory. Additional topics may be included in the training, but they must be in addition to the minimum hourly requirement and may not substitute for required topics. The time allocated for each training topic, breaks and meals, tests, supervised practical training (SPT), and skills performance evaluations must be identified on the schedule. The day the certificates of completion are distributed to the trainees must also be included.

For HHATPs: A schedule is required for each training class type being offered through a hybrid approach: Full Training, Personal Care Aid Upgrading, and Certified Nurse Aide Transitioning.

Policies and Procedures

Policies and Procedures are required and must describe how the hybrid program will be implemented. These should include information specific to the Hybrid Training Program. The “Guidance for Developing Policies and Procedures for a Licensed Home Care Services Agency,” may be helpful and is located on the DOH website at: http://www.health.ny.gov/facilities/home_care/guidance_docs_for_lhcs_applicants.htm 

Policies and Procedures should address the following:

1. Admission/Enrollment Criteria: how students will be selected for Hybrid Training, enrollment details, how required documentation will be obtained.

2. Attendance/Trainee Verification: how attendance will be taken, and the documentation maintained; how trainees’ identity will be verified for attendance, and attendance requirements for Hybrid Training.

3. Curriculum and Learning Materials: how the curriculum will be presented in an online environment, how textbooks and other learning resources will be provided to the trainees, required topics, language in which the course will be taught, learning objectives and time allotted for each module. Hybrid training programs must use the home care curriculum and the approved textbooks. 

4. Technological Platform: description of the platform for the online component, specific equipment needed to access the training and how the system will be tested prior to beginning training. A description of how trainees will access the online training and how the Nurse Instructor will be trained on the use of the technological platform.

Please Note: If your agency chooses to change technological platforms after your initial approval for Hybrid Training, updated Policies and Procedures must be submitted to the Department for approval prior to the change taking place.

5. IT Support: how IT support will be provided to Nurse Instructors and trainees, and how issues with equipment, accessibility or connectivity will be addressed. 

6. Confidentiality: how the confidentiality of student information and training/testing materials will be maintained.

7. Testing: how trainees will be scheduled and monitored for in-person testing.

8. Skills: how trainees will be scheduled for in-person skills assessments and Supervised Practical Training (SPT) and how these will be conducted.

9. Program Monitoring and Evaluation: description of the evaluation design and methodology that will be used to ensure the continued quality of hybrid training. Agencies are encouraged to identify metrics that are demonstrative of the quality of the training.

Personal Care Aide Upgrading and Certified Nurse Aide Transitioning: 

For HHATPs choosing to offer the following in a hybrid training environment, you must also submit:

10. Personal Care Aide Upgrading: how this class will operate in a hybrid training environment with a description of the portion to be taught online and that which will be taught in person.

11. Certified Nurse Aide Transitioning: how this class will operate in a hybrid training environment with a description of the portion to be taught online and that which will be taught in person.

The Department of Health reserves the right to revoke or suspend approval for Hybrid Training due to findings from the surveillance process.

For additional information related to standards related to COVID-19, please refer to Department guidance posted on the Health Commerce System:

Guidance for Home Health Aide and Personal Care Aide Training Programs June 01, 2020; and 

Update: Home and Community-Based Services Regarding COVID-19 Updated June 18, 2020.

COVID-19 related questions should be sent to: covidhomecareinfo@health.ny.gov.

Completed requests for approval of a hybrid training program should be sent via email

PCA Training Programs: pcatp@health.ny.gov 

HHA Training Programs: hhatp@health.ny.gov