Colorado caregiver training: topics, competency checks and supervision

Training every year: four or six topics

• Homemakers: "The HCA shall ensure that ongoing training of homemakers occurs and shall consist of at least four (4) training topics outlined in Part 7.3(C)(1) above every twelve (12) months" after the starting date of employment or by calendar year, as your policy chooses (Ch. 26, 7.3(C)(3)).
• Personal care workers and supervisors: "The HCA shall ensure that ongoing supervisory and direct care staff training occurs and shall consist of at least six (6) topics every twelve (12) months", again from the start date or calendar year (Ch. 26, 7.4(C)(4)). The six must include: "Behavior management techniques and the promotion of consumer dignity, independence, self-determination, privacy, choice, and rights, including abuse and neglect prevention and reporting requirements. Disaster and emergency procedures. Infection control using universal precautions. Basic first aid and home safety." (Ch. 26, 7.4(C)(4)(a)-(d))
• Prorated. "The training requirement shall be prorated in accordance with the number of months the employee was actively working for the HCA." (Ch. 26, 7.3(C)(3); 7.4(C)(4)). The rule does not say how to count months or round. CareRulebook’s manual counts every month with at least one working day and rounds up, so no one does less than their share; that is the manual’s method.
• For everyone, including office staff: training on your emergency preparedness plan at least once a year and when it changes (Ch. 26, 5.10(D)), and on your infection prevention and control policies at least once a year (Ch. 26, 5.13(A)). For personal care workers and supervisors these match two of the six required items. For homemakers, infection control is one of the initial topics they can count; the emergency plan training is not on their list.

Our reading on homemakers. The six-topic rule speaks of “supervisory and direct care staff” and sits in the personal care worker part of Chapter 26, while homemakers have their own four-topic rule. By our reading, a homemaker who gives no personal care owes four topics. Chapter 26 does not define “direct care staff”, so if you want to be safe, give homemakers the six. A personal care worker must also meet the homemaker rules (Ch. 26, 7.4(A)), so CareRulebook’s manual makes at least four of their six yearly topics ones from the homemaker list.

Training from an outside provider

"If the HCA utilizes another entity to provide the training, the HCA must validate that the training program meets the requirements in Part 7.3(C) below and retain evidence of the individual’s successful completion of the training program in the personnel record." (Ch. 26, 7.3(B)(1))

• Check it before you rely on it. The rule names the homemaker topics in 7.3(C). It has no matching sentence for the personal care topics, so CareRulebook’s manual checks those too, on a validation checklist, before the first worker relies on the course, when the course changes and at least once a year, and teaches any missing topic itself. That checklist and its timing are the manual’s procedure.
• The competency checks stay with you. For a personal care worker, the proof of competency before assignment is conducted by "the HCA manager or supervisor" (Ch. 26, 7.4(C)(3)(a)), so an outside course does not replace it.
• Online courses. Allowed for initial training if interactive, with demonstration of learned concepts (Ch. 26, 7.3(C)(1)). Watching videos alone does not meet that, by our reading.

Competency evaluations: what the rule asks, and what it leaves to you

Chapter 26 asks for:

• a competency evaluation "that includes a visual observation and evaluation of relevant skills" for homemakers (Ch. 26, 7.3(B)), and a core competency evaluation of homemaking and housekeeping skills before initial training ends (Ch. 26, 7.3(C)(1)(i));
• a competency evaluation and skills validation, including visual observation, for personal care workers, and the manager’s or supervisor’s proof of competency before assignment (Ch. 26, 7.4(B), (C)(3)): "The HCA is responsible for ensuring that the individuals who furnish personal care services on its behalf are competent to carry out all assigned tasks in the consumer’s place of residence.";
• in each personnel record, qualifications that include an "appropriate, detailed, and observed competency evaluation; and written testing overseen by a person with the same or higher validated qualifications" (Ch. 26, 5.9(B)(2)(a)(i)).

What it leaves to you. Chapter 26 sets no pass mark and no format for these evaluations, and does not say who evaluates a homemaker. CareRulebook’s manual (Policy 4.6) sets its own standard: every step on an observed skills checklist done correctly, and at least 80% on a written test with every wrong answer then gone through until the worker gets it right. The first evaluation happens in the office with training equipment or a colleague playing the client, so no one practises on a consumer, and the manager or a supervisor evaluates. All of that is the manual’s choice. Because the personnel record rule lists written testing, the manual gives every worker the written test as well; that is our reading of 5.9(B)(2)(a)(i).

The HCA manager’s training: 8 hours, then 12 a year

The manager must "have successfully completed an eight (8) hour agency manager training course. Additional related annual training that equals twelve (12) hours shall be required in the first year and annually thereafter" (Ch. 26, 7.2(B)(3)). The rule adds: "A copy of the certificate of completion shall be retained in the HCA manager’s personnel file." (Ch. 26, 7.2(B)(3)(b))

• Which course. A course is approved if it is "conducted by an accredited college, university, or vocational school or by an organization, association, corporation, group, or agency with specific expertise in that area and the curriculum includes at least eight (8) actual hours of training." and covers a home care overview (including the limits of personal care versus health care), regulatory responsibilities (consumer rights, governing body duties, quality management plans, occurrence reporting and complaints), personnel, the needs of fragile, ill and disabled people, and behavior management (Ch. 26, 7.2(D)). CDPHE publishes a List of Approved Trainings (CDPHE), but its page cites rule numbers that no longer match the chapter and describes the 24-hour Class A training (CDPHE). Our suggestion: ask the provider in writing whether the course meets the Class B 8-hour course in 7.2(B)(3) and 7.2(D).
• Experience instead. A new manager may instead show documented and confirmed equivalent job experience or education. "The Department may require additional training to ensure that all the required components of the training curriculum are met." (Ch. 26, 7.2(B)(3)(a))
• 12 hours a year. The rule calls it “additional related annual training”, so by our reading the 8-hour course does not count toward the first year’s 12 hours. It does not say how to count the year; CareRulebook’s manual counts from the date the manager started in the role.
• Proof at the survey. CDPHE expects "Proof of administrator/manager training and qualifications, as applicable" at the initial survey (CDPHE guidance, step 6).

The manager is also responsible for ensuring "the implementation and monitoring of the HCA’s training program for all homemakers and personal care workers, including managing or delegating employee training and development activities for the HCA" (Ch. 26, 7.2(C)(11)), and makes sure new personnel are oriented and in-service education is provided (Ch. 26, 7.2(C)(6)). The manager’s qualifications are on the manager and supervisor page; CareRulebook’s manual covers them in Policy 1.2.

Training records

"Documented evidence of trainings, competency testing, and skills validation shall be documented with the date of training; length of training; entity or instructor(s) that offered or produced the training; a short description of the content; and staff member's written or electronic signature or proof of attendance." (Ch. 26, 7.6(A)(1)) "The HCA shall maintain evidence of training, competency testing, skills validation, and related certificates along with proof of completion in each individual’s personnel file." (Ch. 26, 7.6(A)(2))

A returning employee can skip initial training only if their earlier orientation, training and personnel action records are still on file (Ch. 26, 7.5(A)(1)(d)), which is a reason to keep a leaver’s file. CareRulebook’s manual keeps one training record per worker, a yearly training log, and a competency record listing the tasks each worker may be assigned and when any yearly check is due, so the supervisor can check it against the service plan before assigning them.