F0726

E

Widespread Failure to Complete Hiring, Orientation, and Competency Validation for CNAs and Nurses

Jackson, Michigan Survey Completed on 01-13-2026

Penalty

No penalty information released

Summary

The deficiency involves the facility’s failure to ensure that nurses and CNAs possessed and demonstrated required competencies and that hiring, background checks, and orientation processes were completed as required by state and federal regulations. Surveyors’ interviews and personnel file reviews showed that a CNA hired and later terminated within a two‑month period had no completed orientation plan or new hire paperwork in her file, including no background check, certification verification, I‑9, fingerprinting, drug screening, or pre‑hire physical. When asked, the DON initially produced only a freshly printed, blank general orientation form and could not provide completed orientation, competency check‑offs, or required CNA‑specific training documentation for this CNA. The Human Resource Coordinator (HRC) confirmed that this CNA’s new hire process and CNA‑specific trainings were not completed and that she had not been checked off on any required competencies such as abuse/neglect, transfers, ADLs, infection control, residents’ rights, dementia care, change in condition, skin assessments, behavior management, elopement risk, bowel and bladder, hospice, hemodialysis program, bed mobility, body mechanics, gait belts, CNA documentation, cleaning equipment, respiratory care, emergency care, abdominal thrusts, code status, and unit orientation.

Further review of personnel files for a sample of 19 CNAs hired over a six‑month period revealed widespread omissions in required hiring and orientation documentation. Multiple CNAs had incomplete or unsigned new hire checklists, no reference checks, no I‑9 forms, no I‑CHAT background checks, no sex offender registry checks, no eligibility letters, no certification verifications, no TB tests, no documentation of active driver’s licenses, and no evidence of completed facility general orientation. CNA‑specific competency evaluations were consistently missing, and there was no verification that orientation was completed before CNAs were scheduled to work on the units. One rehired CNA had only an I‑CHAT background check completed at rehire, with no updated competencies, no certification verification, and no clinical oversight to determine training needs, yet was placed on the schedule. Another CNA completed her own competency skills check‑off and signed it as passed without any nurse or management validation or signature.

Interviews with leadership and staff confirmed that unvalidated staff were working independently with residents. The HRC stated he was unaware of federal regulations in the State Operations Manual and was learning CNA education and training requirements during the survey. He described a process in which he conducted a one‑day general orientation and then sent new hires to the DON or ADON for job‑specific orientation and unit shadowing, but there was no documentation that competencies were actually completed before staff were released to work. The DON acknowledged that CNA competencies had not been done prior to her arrival, that she had no log or proof of completed competencies, and that she was aware CNAs were working with residents without required training and competencies but could not remove them from the floor due to staffing needs. A CNA reported she went from shadowing other CNAs directly to being scheduled on the floor without a nurse checking her use of equipment or transfers. The scheduler confirmed she had no checklist to verify completion of orientation or competencies and simply scheduled CNAs once they stated they were done orienting, and she reported receiving no training on competency requirements.

Similar deficiencies were identified in the hiring and orientation of licensed nurses. Personnel files for several RNs and LPNs hired in the same six‑month period showed new hire checklists either blank or minimally completed, with missing I‑CHAT background checks, eligibility letters, sex offender registry checks, nursing license verifications, I‑9 forms, TB tests, physicals, and drug screenings. There was no evidence of completed facility general orientation or nursing‑specific competency evaluations, and no verification that orientation was completed before these nurses were scheduled to work on the units. In one case, only the nursing license verification, I‑CHAT background check, and sex offender list verification were present, with no orientation plan or health screening documentation. Overall, the survey findings document that both CNAs and nurses were hired and placed on the schedule without completed regulatory hiring elements, orientation, or validated competencies necessary to safely meet residents’ assessed needs and care plans.