On April 8, 2026, the Centers for Medicare & Medicaid Services (CMS) issued a memorandum clarifying requirements and allowable flexibilities for Nurse Aide Training and Competency Evaluation Programs (NATCEP) and Nurse Aide Competency Evaluation Programs (CEP). The guidance is intended to support expanded nurse aide training capacity and strengthen staffing in nursing homes, as part of CMS’s Nursing Home Staffing Campaign.
CMS reiterates that NATCEP and CEP programs remain subject to federal requirements governing nurse aide training and competency evaluation in skilled nursing facilities. The memo confirms that nurse aides cannot be charged for any part of training or competency evaluation if they are employed by, or have received an offer of employment from, a facility at the start of training. It also reiterates that individuals who obtain employment within 12 months of completing training must be reimbursed on a pro rata basis for allowable costs, and that states may not charge fees for nurse aide registry listing.
The guidance confirms that NATCEP programs must include at least 75 hours of training, including a minimum of 16 hours of supervised practical training. CMS clarifies that practical training may occur in a variety of settings, including long-term care, acute care, or vocational settings, and must be conducted under the direct supervision of an RN or LPN.
CMS also clarifies supervision standards, noting that students may only perform tasks they have been trained and deemed competent to perform. Once proficiency is demonstrated, they may provide services under general supervision of an RN or LPN, meaning oversight is required but does not require direct, in-person observation at all times.
Instructor qualification requirements are also clarified. Training must be provided by or under the general supervision of an RN with at least two years of experience, including at least one year in long-term care. However, CMS allows flexibility for instruction to be provided by RNs without this full experience requirement if they operate under the general supervision of a qualified RN. All instructors must have completed, or have experience in, adult education or nurse aide supervision, and additional instructional staff must have at least one year of relevant experience.
For competency evaluation, CMS confirms that states may use remote technology for written or oral exams, allowing multiple candidates to test simultaneously. Remote technology may also be used for skills observation if evaluators can clearly observe performance as they would in person. However, all regulatory requirements must still be met, and skills evaluations must be conducted by a qualified RN with appropriate experience.
The memo also emphasizes that resident consent must be obtained before any observation involving residents, including remote training or evaluation. Consent may be verbal or written, but verbal consent must be documented.
CMS further encourages states to improve access to NATCEP information, including the use of Civil Money Penalty (CMP) funds to enhance websites and streamline access to training programs. States may apply for funding to support these improvements through CMS’s Nursing Home Staffing Campaign processes.
Finally, CMS reiterates that inadequate training or supervision may lead to resident harm and potential noncompliance findings for facilities. In certain cases, facilities that lose NATCEP/CEP approval may regain eligibility through waiver processes.
The guidance is effective immediately and should be communicated to all appropriate staff within 30 days. The full memorandum is available here.
Compliance Perspective
Issue
CMS issued a memorandum clarifying requirements and allowable flexibilities for NATCEP and CEP. The guidance reinforces existing requirements, including training standards, supervision, instructor qualifications, competency evaluation procedures, and fee restrictions. It also clarifies allowable use of remote technology for training and testing, as well as expectations for resident consent and continued compliance with 42 CFR Part 483, Subpart D. CMS emphasizes that despite added flexibilities, facilities remain responsible for ensuring nurse aides are adequately trained to safely meet resident care needs.
Discussion Points
- Review and update facility policies and procedures related to nurse aide training programs to ensure alignment with current CMS requirements, including training hours, supervision standards, instructor qualifications, fee restrictions, and competency evaluation processes. Policies should clearly reflect expectations for both in-person and remote training components, as well as documentation of resident consent when applicable. Facilities may benefit from an objective review of existing training program structure and compliance processes through external consultant support or a structured mock survey approach to identify potential gaps and ensure regulatory readiness.
- Provide staff education on updated NATCEP/CEP requirements, including training standards, supervision, and competency evaluation expectations, and appropriate use of remote training technology and resident consent requirements. Med-Net Academy offers the course Employee Recordkeeping Requirements and Education, which covers essential staffing and competency requirements for skilled nursing facilities. The course reviews staff competency expectations, including recognition and response to changes in resident condition, as well as applicable license and certification requirements for healthcare personnel. It also addresses employee responsibilities related to documentation and recordkeeping, including general compliance requirements and maintaining accurate staffing and competency records to support quality care.
- Conduct targeted audits of nurse aide training activities where applicable to verify compliance with updated requirements, including documentation of training hours, supervision records, competency evaluations, and instructor qualifications. Audits should also assess consistency in application of policies and identify potential risk areas related to training quality or resident safety. Facilities may benefit from structured mock surveys or focused program reviews conducted with external consultant support to validate compliance and strengthen ongoing quality assurance processes. Contact Med-Net Healthcare Consulting or info@mednetconcepts.com for more information.
*This news alert has been prepared by Med-Net Concepts, Inc. for informational purposes only and is not intended to provide legal advice.*