The requirement for initial training within seven business would be impossible. As a small agency, we do not have in-house trainers for medication administration or CPR/First Aid, so we rely on outside agency schedules. Clarification on whether all part time staff must be certified in medication administration--if so, this creates another undue burden on a small agency, as well as those staff. Part-time staff often work another full time job, and being required to take a week off to attend a medication administration class might be so onerous that they choose to find employment elsewhere. 

The proposed requirement for annual retraining would be a heavy financial burden to a small agency, specifically in a field with retention rate of 60% over 2 years. If the expectation for annual trainings (including CPR/First Aid and Med Management) remains and the reimbursement rates do not change, small providers will be absorbing these costs (see Christy Collins comment for specifics on the cost for our agency). In addition to current required annual trainings, this agency has offered various other trainings to staff  (Nutrition, Active Shooter, Grief and Loss, Crisis Intervention), which often require this agency to pay overtime to employees and creates a loss in revenue as services are not provided for that time period. Any increase to required annual training should be done on an agency by agency basis where deficiencies are noted rather than an overarching mandate for all providers who are monitoring and providing remedial training to employees as needed.