Remove the proposed regulation that requires that providers obtain a professional reference for a nurse aide applicant who has only worked for 1 employer. Providers have found that many employers are unresponsive to reference requests. The requirement will eliminate a percentage of potentially qualified workers because of the inability to get a response from a former employer. Given the shortage of nurse aides this would further limit the pool of potential workers needed to cover cases. We ask that personal references continue to be allowed.

Remove the requirement that nurse aides "physically attend" 12 hours of in-service education anually.Providers should be allowed to continue to utilize printed material and other mediums.  It is effective and sufficient  to require  RN supervisors provide instruction in the home during home visits  when nurse aide deficiencies in knowledge are identified that are recipient specific.

Remove the requirement that signatures times and dates be placed on the record no later than 7 calendar days from the last date of service. In many cases it will be  impossible to comply with standard, and in cases in which the signature cannot be obtained in this time frame, there is no remedy for the provider preventing  the provider from the ability to bill for  services that were appropriately rendered.  For example, the client is hospitalized or leaves town without notice and doesn't return home for many weeks. There are many other examples providers can give in which it takes many weeks and longer to obtain a signature from a recipient.