F0728

E

Uncertified Nurse Aides Used as Independent Direct Care Staff

Chico, California Survey Completed on 01-14-2026

Penalty

No penalty information released

Summary

The deficiency involves the facility’s failure to ensure that nurse aides (NAs) were properly certified, trained, and deemed competent before independently providing direct resident care. The facility’s own undated Nursing Assistant Job Description stated that uncertified NAs were expected to provide routine daily nursing care only in areas where they had received clinical instruction and demonstrated competence, and that general direct resident care duties could not be performed until theory and competency skills were accomplished. The job description also required that NAs be enrolled in a state-approved Nurse’s Aide Training Program (NATP) and maintain clinical competency while enrolled. However, record review showed that Facility 3 did not have a California Department of Public Health (CDPH)–approved NATP or serve as a clinical training site, despite employing NAs in training and assigning them to direct care roles.

Surveyors’ review of hiring dates, NATP graduation dates, and state certification dates for seven NAs showed that multiple NAs were assigned to independent resident care duties before they were state certified. NA 1, NA 2, and NA 3 were hired, later graduated from NATP, and became certified on a later date, but were assigned to resident care—sometimes unpaired with a CNA—before certification. NA 4 was hired and remained uncertified for months while being scheduled to work independently on a unit without pairing to a specific CNA. NA 5 graduated from NATP but never became certified before resigning, yet was assigned to independent unit work and 1:1 resident care. NA 6 and NA 7 had graduated from NATP and remained uncertified; they reported working as NAs at Facility 3 until certification, and were observed at the facility on a scheduled shift, although they did not appear on the written schedule provided for review.

Interviews with staff further demonstrated that uncertified NAs were being used as direct care providers. The Director of Staff Development (DSD 1) stated that graduated NAs could do everything a CNA could do except operate machinery like a Hoyer lift, and that they could perform 1:1 care, accompany residents to appointments, and “pretty much everything a CNA can do.” The scheduler confirmed that NAs were scheduled full time and placed into CNA rotation slots. The NATP instructor and DSD 2 from Facility 2 stated that uncertified NAs were not supposed to provide hands-on care without CNA or licensed nurse supervision and that they were unaware NA graduates were not permitted to work at Facility 1 or 3 prior to certification. NA 3 reported performing direct resident care, including touching and changing residents with CNA supervision, and described confusion about what NAs were allowed to do, noting that the facility had not assessed skill competencies or provided orientation during their work as an NA. The Governing Body’s representative acknowledged that Facilities 1 and 3 were not approved NATP sites and agreed that NAs should not be feeding and changing residents, while also confirming that the Administrators and Governing Board were responsible for ensuring NATP and NA hiring followed federal and state regulations.