Most of what a Director of Staff Development is judged on is not the teaching. It is whether the paperwork behind the teaching exists, says the right things, and can be found while somebody is standing at your desk waiting for it.
The record each CNA is owed
Note the duty-holder: it is the facility, agency or public educational institution — not "the facility" loosely, and not the individual aide. The record has prescribed contents, and two of them are the ones people most often leave off:
- the participant's name and CNA certification number;
- the programme title;
- the date and the hours attended;
- the name, address and telephone number of the organisation providing the training;
- the name, professional title and signature of the Director of Staff Development or Instructor;
- the provider identification training number issued by the Department; and
- a statement that the record is to be retained by the certified nurse assistant for four years from the date of enrollment.
Retention
Section 71847(i) requires the programme's records to be retained for four years. Section 71849 likewise tells the CNA to keep their own copy for four years from enrollment. Four years is therefore the working answer for in-service documentation, and it is longer than most facilities' default document-retention habits — so setting a four-year retention habit up front keeps you covered.
The tags a surveyor checks
In a facility certified for Medicare or Medicaid, a survey produces findings against F-tags. A few of them are yours whether or not your name is on them:
| Tag | Regulation | What it is about |
|---|---|---|
| F726 | 42 CFR § 483.35, incl. (c) | Competency. Nurse aides must be able to demonstrate competency in the skills and techniques needed to care for residents' needs, as identified through assessments and the plan of care. |
| F730 | 42 CFR § 483.35(d)(7) | An annual performance review of every nurse aide, with in-service education based on its outcome. Cited when that linkage is missing. |
| F947 | 42 CFR § 483.95(g) | The required in-service training itself, including the 12-hour floor and the dementia and abuse-prevention content. |
| F880 | 42 CFR § 483.80 | The infection prevention and control programme. |
| F689 | 42 CFR § 483.25(d) | Accidents and supervision — where transfer and equipment training tends to surface. |
Attendance, completion, competence
These are three different claims, evidenced three different ways, and conflating them is the most common substantive failure in staff development records.
- Attendance — this person was in the room. A signature sheet proves it.
- Completion — this person finished the material. A post-test or a completion record proves it.
- Competence — this person can perform this skill. Only an observation of them performing it proves that.
A competency finding needs to be per person and specific enough to stand up on its own: this individual, this skill, this date, satisfactory or not, judged by someone already competent in it. A roster of twenty names against "Safe Transfers — 1 hour" is an attendance record. It is not evidence that any of those twenty can use a mechanical lift.
CMS does not prescribe a single acceptable method. Appendix PP introduces its list of ways to evaluate competency with the words "Examples for evaluating competencies may include but are not limited to" — an open list. Unannounced observation during actual care is legitimate, and is often the strongest evidence you can hold. The test is not whether your method appears on somebody's list; it is whether it produces a per-person finding you can show.
A quick self-audit to walk in survey-ready
Pick one CNA at random and one in-service session from the last twelve months, and see how far you get:
- Can you produce the lesson plan for that session, with student performance standards, topics in sufficient detail, the teaching method, and the method of evaluating results (22 CCR § 71847(d)(2))?
- Can you show what drove that topic — a performance review, a resident need, or a finding from the last survey (§ 71847(f))?
- Can you produce that CNA's record of attendance with all seven required fields, including the provider identification number and your signature (§ 71849)?
- Can you show their hours from their own employment date, not the calendar year, and confirm they are not below the federal 12?
- For any hands-on skill in that session, can you produce a per-person competency finding rather than a roster?
- Is your in-service programme approval current, renewed within the last two years (§ 71847(h))?
Whichever of those six you cannot answer in a couple of minutes is the one to fix this month. In our experience the fourth and fifth are where most facilities stop — the anchor-date problem and the attendance-versus-competence problem.
If you are new to the role and working out what you are accountable for, § 71829 is the section that defines the post and a sensible place to start.
Frequently asked questions
What in-service record is each CNA owed, and who must provide it?
Under 22 CCR § 71849, the nursing facility, agency or public educational institution — not the individual aide — must provide each certified nurse assistant with a record of attendance for in-service training and continuing education.
Which two required fields on the § 71849 record get left off most often?
The provider identification number issued by the Department and the signature of the Director of Staff Development or Instructor. A record missing them may be rejected when the CNA comes to renew — which is easy to avoid once you know the two fields that matter.
How long must in-service training records be kept?
Four years. Section 71847(i) requires the programme's records to be retained for four years, and § 71849 tells the CNA to keep their own copy for four years from the date of enrollment. This is longer than most facilities' default retention habits, so a simple four-year retention habit keeps you covered.
Does a signed attendance sheet prove competence?
No. A signature sheet proves attendance — that the person was in the room. Competence, that the person can actually perform the skill, is proved only by observing them perform it.
What does a valid competency finding have to show?
It has to be per person and specific: this individual, this skill, this date, satisfactory or not, judged by someone already competent in it. A roster of twenty names against a topic like "Safe Transfers — 1 hour" is an attendance record, not evidence that any of them can use a mechanical lift.
Which F-tags can a survey put on the Director of Staff Development's desk?
F726 (competency), F730 (an annual performance review with in-service education based on its outcome), F947 (the required in-service training itself, including the 12-hour floor and the dementia and abuse-prevention content), F880 (infection prevention and control), and F689 (accidents and supervision).
Is § 483.35(e)(7) the correct citation for F730?
No. The Code of Federal Regulations places regular in-service education at § 483.35(d)(7); subsection (e) is a waiver provision about licensed-nurse coverage. A citation to (e)(7) resolves to a real but unrelated sentence, which is worse than no citation because nobody checks it.
Does CMS require one specific method for evaluating competency?
No. Appendix PP introduces its list with the words "Examples for evaluating competencies may include but are not limited to" — an open list. Unannounced observation during actual care is legitimate and often the strongest evidence; what matters is that your method produces a per-person finding you can show.
What must the lesson plan for an in-service session contain?
Under 22 CCR § 71847(d)(2), the lesson plan needs student performance standards, topics in sufficient detail, the teaching method, and the method of evaluating results.
How should a CNA's in-service hours be counted?
From the CNA's own employment date, not the calendar year, and they must not fall below the federal 12 hours. This anchor-date problem is one of the two places most facilities stop when they self-audit.
