HHA Competency Requirements: Documentation Checklist for Home Health Agencies

What the federal rule requires

42 CFR §484.80(c) establishes the competency-evaluation standard for home health aides. Certain subject areas must be evaluated by observing the aide perform the task with a patient or pseudo-patient; other areas may be evaluated through written, oral, or observational methods as permitted by the rule.

The competency evaluation must be performed by a registered nurse in consultation with other skilled professionals, as appropriate.

The documentation itself matters

42 CFR §484.80(c)(5) requires the HHA to maintain documentation demonstrating that the competency-evaluation requirements have been met. A completed record should make it easy to identify who was evaluated, who evaluated them, when the evaluation occurred, which areas were assessed, and the result.

What survey findings show

CMS deficiency records include examples where agencies were cited because aide competency documentation was incomplete or because required competency-evaluation elements were not demonstrated in sampled personnel records. That makes competency documentation a high-value item for internal file audits.

Practical competency file checklist

• Aide identity and role are clear.
• Evaluation date is documented.
• RN evaluator is identified.
• Required skill/subject areas are accounted for.
• Observation requirements are documented where applicable.
• Outcome and any remediation are recorded.
• The record is retrievable with the rest of the personnel file.