FTag of the Month: Training Requirements

May 26, 2023
Polaris Group
May 26, 2023

Ongoing training is key to ensure competent staff, volunteers, and students who can provide the best care to residents.

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In October 2022, CMS added new guidance, including significant changes, to FTag 940. With these new changes, there is even greater clarity that skilled nursing facilities must develop, implement, and maintain an effective training program for numerous individuals that both directly work in and work with the facility. The new training guidelines are now applicable to these parties:

  • All new and existing staff
  • All individuals providing services under contract, including agency staff, third party vendors, outpatient therapists, and hospice providers
  • All volunteers
  • Students in any capacity (nursing students, nurse aid students, student ambassadors)

Ensuring your facility has a thorough training plan

Step 1:  Determine the amounts and types of training necessary for all the various parties to whom this training requirement is applicable.

Despite some vagueness in the directive, CMS has clarified that all facility staff need to receive training on how to interact with residents in a manner that enhances their quality of life and helps residents achieve their highest level of wellbeing.

Training expectations should be consistent and reflect requirements and specific skills needed for the type of role the person will have in the facility. For example, some staff should receive more in-depth training, while a more general training program could suffice for volunteers.

Step 2: Determine the frequency and method of training, as well as the optics.

Most facilities cover general training programs through their orientation process. Facilities should also determine what topics would be covered in annual competency trainings and what could be covered via monthly in-services.

Certainly, training needs should be adaptable and change due to needs in the facility. As a result, CMS has provided some flexibility in training requirements, however, CMS has several “must haves” for staff training. Be sure that your facility has the following topics covered:

  • Cultural competency: ensuring that staff learns of and provides care according to resident preferences and customs
  • Substance abuse: making certain staff are aware of how to provide care to residents as it relates to possible substance use disorders
  • Trauma-informed care: confirming that staff have a process for identifying residents with a history of trauma, understand individualized triggers that affect residents, and how to avoid re-traumatizing residents during care
  • Advance directive planning: verifying that staff know the different types of code statuses and the specific terms of the advance directives for each residents.

Step 3: Determine the overall facility training plan.

Surveyors will look to see that each facility has a written, measurable, and descriptive training curriculum to address residents’ needs and preferences. Here is what your facility should do to prepare a training program that will meet surveyor requirements for Ftag 940:

  1. Update your Facility Assessment quarterly and solicit feedback from the Leadership team and QAPI committee members to update as needed.
  2. Work with HR and Staff Development team members to create an annual training calendar that focuses on content and quality care topics for review each month.  
  3. Share the annual training calendar at QAPI meetings for compliance review and necessary updates.
  4. Ensure employees, volunteers, and contracted employees receive written summaries of training content and that they sign attendance sheets for surveyor perusal.
  5. Communicate your efforts to train and educate personnel with residents and family members.  Engage in conversations with these residents and family members to gain insights into areas of further training needs.
  6. Keep organized records of trainings provided for a minimum of three years.

Ongoing training is key to ensure competent staff, volunteers, and students who can provide the best care to residents. For help optimizing your training program, reach out to Polaris Group consultants.

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