Start with role qualification evidence
CMS requires HHAs to employ qualified personnel. Organize the records your agency relies on to establish qualifications for each role, and make sure expired or superseded items do not obscure the current evidence.
For aides, connect training and competency records
For home health aides, the personnel file should make it easy to trace training and competency evidence required by 42 CFR §484.80. Keep the documentation organized so a reviewer does not have to infer whether the requirements were satisfied.
Common file categories to audit
- Identity and employment records required by your agency
- Role qualification and credential evidence
- Orientation records
- Required screenings or health records under applicable rules/policies
- Competency documentation
- In-service and continuing training history
- Performance or supervisory documentation required by your policies or applicable law
- Corrective-action records, when applicable
Use sampling, not wishful thinking
Choose a random sample of active employee files and review them the same way a third party would. CMS deficiency reports include examples where sampled personnel records did not demonstrate required qualifications or contained incomplete competency and orientation documentation.
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