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.