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IDPH Question and Answers from 2023 Annual CNA Instructors Conference

Questions and answers have been added below. They are in an accordion format. Please click on the question or the “+” symbol to the right of the question to expand the answer area. 

I teach at the high school level. I am in danger of my program ending (because of school administration) because I don't have enough students signing up. When I have talked to potential students they say it is because they are not getting the vaccination. REGARDLESS of one's views on this, what is your advice? I know some schools require vaccination for nursing school; however, our local community college does not. Is there any hope of the mandate ending in the long-term care facilities?

I assume this is about the COVID vaccine. This is an example of why it is so important to read the monthly updates. The requirement is and always has been since 2021 either COVID vaccination or frequent testing. The only time a COVID vaccine is a requirement would be if the clinical partner requires it.

Individuals covered by the requirement to be vaccinated can choose to be tested on a weekly basis rather than be vaccinated. An individual does not need to qualify for a medical or religious exemption in order to opt for testing instead of vaccination. However, an employer may choose to impose stronger health and safety requirements beyond the requirements of the Executive Order. This could include requiring all employees to be vaccinated without the option of testing, except for those with a medical or religious exemption.

Quote from the IDPH SARS COV-2 informational site:

Does IDPH have guidelines as to what vaccines are necessary for clinicals? What about the COVID vaccine? How many doses?

There are no mandated vaccines from IDPH from clinical attendance. The vaccination requirements come from the clinical partners. If your clinical partner requires a vaccine that a student refuses (especially COVID), they can opt for testing or you would have to find a clinical partner that allows testing over vaccination.

Please confirm the federal regulation regarding tuition reimbursements to students if they pay out of pocket for training when hired as CNA at a Medicare Nursing Home.

4132.2F – Prohibition of Charges (Medicare State Operations Manual
(Rev. 1, 05-21-04)
No nurse aide who is employed by, or who has an offer of employment from, a facility on the date on which the aide begins a NATCEP may be charged for any portion of the program (including any fees for textbooks or other required course materials). If an individual who is not employed or does not have an offer to be employed as a nurse aide becomes employed by or receives an offer of employment from a facility not later than 12 months after completing a NATCEP, the State must provide payment for costs incurred in completing the program on a pro-rata basis during the period in which the individual is employed as a nurse aide.

42 CFR 483.152 Prohibition of charges.

(1) No nurse aide who is employed by, or who has received an offer of employment from, a facility on the date on which the aide begins a nurse aide training and competency evaluation program may be charged for any portion of the program (including any fees for textbooks or other required course materials).

(2) If an individual who is not employed, or does not have an offer to be employed, as a nurse aide becomes employed by, or receives an offer of employment from, a facility not later than 12 months after completing a nurse aide training and competency evaluation program, the State must provide for the reimbursement of costs incurred in completing the program on a pro rata basis during the period in which the individual is employed as a nurse aide.

How long can we use the 5th edition of Hartman since there's a new edition out?

IDPH does not mandate which textbook or which edition you may use. If new information in a new edition is very different from a research standpoint than a previous edition, it is important to use the most current edition. Keep in mind that the textbooks are meant for a national audience so there may be information in the text that is not applicable to Illinois CNAs. Follow the Model Program Curriculum or your own curriculum. IDPH monitors changes based on new research (evidence-based practice or EBP) that is published through the CDC. There have, to date, been no updates on any of the mandated skills, for example.

Since we are allowing students with Individual Taxpayer Identification Number (ITIN) to register for the BNATP and take the INACE, and ITIN does not give an individual work authorization, please explain how they would use their CNA if they are not authorized to work with an ITIN?

This is something that IDPH emphasized multiple times through the legislature that allowing students to use an ITIN would not increase the number of CNAs or nurses in Illinois. The student would not be able to utilize a CNA certification if they do not have work authorization. If they had work authorization, they would have a regular SSN that may be marked “valid for work authorization only.”

Will there be a program coordinator workshop in the near future? Or an instructor skills boot camp for new instructors?

Yes! Beth, Tabitha, and Randy are working on regular online live training for Program Coordinators that we can offer as often as necessary. We will create some type of signup for instructors interested in this training. The Train the Trainer programs through CNAEA and SICU all offer a lot of this information, and they also have skills workshops included. The current contract being negotiated between SIUC and IDPH includes a third Education Coordinator position which will allow each one to do fewer monitoring visits and more education sessions.

Re: colostomy clarification. What is the CNA allowed to do? RE: drains i.e., JP, Hemovac. Can a facility train how to care for them? Thank you

CNAs can empty colostomy bags in Illinois. They cannot change appliances. CNAs in most settings cannot do anything that is not in the Model Program, included drains. However, hospital regulations are different than long-term care or assisted living facilities. A hospital can teach a CNA additional skills as long as they have a training program, document competencies, and keep the documentation in an employee’s training record. An IDPH or TJC surveyor can require a live demonstration of new skills as part of their
survey activities.

RE: college student with incomplete. Is there a certain amount of time allowed to complete BNA Program and take state competency? Thank you

This is entirely up to the BNATP. If a student has to withdraw for some reason (illness, pregnancy, etc.) it is up to the individual school’s policies on whether a student has to repeat an entire program or can pick up where they left off when they received the

What is the instructor/student ratio for classroom labs?

1:16 for lab instruction, but no more than five students per lab bed.

RE: apprenticeships. What is the status? Thank you

The CNA-A program is fully funded. We are awaiting two new hires to monitor the pilot program and to move it into full implementation after the pilot has ended when it will be opened up to most providers. We don’t know how many BNATP/facility partnerships will be opened because that is the point of the pilot to determine future needs. We will need more than the initial ten partnerships, so if you are interested, please contact your clinical
partner and then send Randy an email stating your interest. Please do this ASAP.

Facilities have indicated that IDPH is requiring enhanced barrier precautions (precautions between standard and contact for any resident with an open wound or invasive device such as an indwelling catheter or feeding tube. This is the use of gown and gloves when performing activities such as emptying the catheter drainage bag, bathing, etc. according to facilities. Is this required, recommended? Some facilities are following, and some are not. Should this be incorporated into our CNA curriculum?

Enhanced barrier precautions (use of a gown and gloves) are required for those residents at risk for spreading an MDRO either through an infected wound or through an invasive device such as an indwelling catheter or feeding tube. When the wound is healed or the device is removed, the enhanced barrier precautions are no longer required. The enhanced barrier precautions are to be used in the following activities:

• Dressing
• Bathing/showering
• Transferring
• Providing hygiene
• Changing linens
• Changing briefs or assisting with toileting
• Device care or use: central line, urinary catheter, feeding tube, tracheostomy/ventilator
• Wound care: any skin opening requiring a dressing

Section 300.696 Infection Prevention and Control
d) Each facility shall adhere to the following guidelines and toolkits of the Centers for Disease Control and Prevention, United States Public Health Service, Department of Health and Human Services, Agency for Healthcare Research and Quality, and Occupational Safety and Health Administration (see Section 300.340):
14) Implementation of Personal Protective Equipment (PPE) in Nursing Homes to Prevent Spread of Novel or Targeted Multidrug-resistant Organisms (MDROs)


Enhanced Barrier Precautions expand the use of PPE and refer to the use of gown and gloves during high-contact resident care activities that provide opportunities for transfer of MDROs to staff hands and clothing [11-15]. MDROs may be indirectly transferred from resident-to-resident during these high contact care activities. Nursing home residents with wounds and indwelling medical devices are at especially high risk of both acquisition of and colonization with MDROs [3,5,6]. The use of gown and gloves for high-contact resident care activities is indicated, when Contact Precautions do not otherwise apply, for nursing home residents with wounds and/or indwelling medical devices regardless of MDRO colonization as well as for residents with MDRO infection or colonization.

Examples of high-contact resident care activities requiring gown and glove use for Enhanced Barrier Precautions include:
• Dressing
• Bathing/showering
• Transferring
• Providing hygiene
• Changing linens
• Changing briefs or assisting with toileting
• Device care or use: central line, urinary catheter, feeding tube, tracheostomy/ventilator
• Wound care: any skin opening requiring a dressing

In general, gown and gloves would not be required for resident care activities other than those listed above, unless otherwise necessary for adherence to Standard Precautions. Residents are not restricted to their rooms or limited from participation in group activities. Because Enhanced Barrier Precautions do not impose the same activity and room placement restrictions as Contact Precautions, they are intended to be in place for the duration of a resident’s stay in the facility or until resolution of the wound or discontinuation of the indwelling medical device that placed them at higher risk.

Could you go over the master schedule and the new "lab hours" and how that should look.

For BNATPs only providing the minimum required education of 80/40, the eighty hours of theory/lab is split into minimum hours of 64 theory and 16 lab hours. Per the Model Program, there are 62 mandatory hours which would leave 18 hours for lab. Either way is correct

Is it possible to change the age on when students can press the button on lifts? I teach Juniors and Seniors and many of them are not 18.

No, this will not happen. This is a Department of Labor standard. It was revisited at the request of training programs and facilities around the country and the DOL is adamant that anyone
under 18 should not be using mechanical lift equipment. The on-the-job injuries for 16- and 17- year-olds has risen steadily in the last few years and their occupational nurses and physicians feel that this standard must remain in place. If a student is under 18, they can be the second person on a lift team, but not the primary operator.

with secondary education do you feel dual credits with a college is good for students and instructors?

This is only my personal opinion, not that of IDPH, but anything that encourages a student to continue their education is a good thing. It also gives the instructors in secondary programs, often the only person in the program, some additional instructional support as you would have to meet the college’s criteria for students to receive dual credit.

Is there any opportunity to get individual guidance and support for starting in house "resident attendant" program? Or are there any place employees can be sent to take this course?

Some of the Train the Trainer program instructors also offer Resident Attendant training which is IDPH approved. There is one program in the state, taught by an experienced BNATP instructor, that travels from facility to facility to teach the Resident Attendant (RA) students. I do not know how far she is willing to travel or the costs of any of the program.  You could probably post a general question to the CNAEA website or ask a representative here today about this.

The American Health Care Association (AHCA) has a feeding assistant program for purchase that is approved by IDPH. It does not have the personal care training (washing, shaving, oral care, etc.) that is required in Illinois, so you would have to create that portion of the program. Facilities creating these programs often use the skills manual and skills checklists because these additional skills are covered individually in the BNATPs.

Who should we report to when there is no cooperation from Nursing Home for the CNA's Clinical Site. Most Time ignored

This question requires more clarification. Cooperation in what respect? If a clinical site is not providing the resources and resident availability for your training, you would need to talk to the facility administrator or identify a new clinical partner. This is why the site agreements between the BNATP and the facility are important. They provide a specific contract on the responsibilities of each party.

Why are you changing the recertification policy, that approved evaluators cannot evaluate?

We have approximately 4000 CNA recertification applications annually and only about 10% actually complete the skills exam and retake the certification exam. Too many evaluators are charging ridiculous fees that a CNA cannot afford. When we interviewed those who applied, but did not test, the only answer we were given was that they cannot afford the skills evaluation test. We need to get more CNAs into the workforce or back into the workforce and this is a simplification of that process. We did not have any issues with recertifying CNAs who had lapsed for five years or fewer during the pandemic and that gave us the data we needed to change the certification process

Will students still be required to have Covid vaccination to participate in long term facilities?

Only higher education students (college programs) were required to be vaccinated. The rule has always been vaccinate or test frequently. Many facilities, wishing to protect their residents/patients further, required that clinical students get vaccinated. Some still do
require that.

In secondary (high school) programs, we know that background checks are not required. If students do not get a background check, will their test results show up on the publichealth care worker registry? Many years ago, they did not, and long-term care employers had to call IDPH to verify CNA status.

The failure for the certification exam to show up on the registry is a failure of the BNATP to enter the student demographics including training dates. This has always been a requirement (at least since 2010) and many programs are still failing to do this.

I have a student who is enrolling in the BNA program in the fall, and she has a disability. She has a deformity in one of her hands and I am nervous she will not be able to do BP or ambu-bag for CPR... do you know of any accommodations for disabled students, if any?

The ADA requires reasonable accommodation, not extraordinary accommodation. You can, for example, allow this student to take a blood pressure with an automatic cuff. The American Heart Association has a new certification called Advisor: BLS which allows them to talk through CPR with an instructor. This is allowable, but their job search would depend on whether they are able to perform full CPR

The age for students to work as a CNA was dropped to 17 during covid and now I am seeing a lot of facilities go back to hiring 18+ for CNA's... is this the trend statewide?

There was never a new requirement to lower the age of CNAs. It was likely due to a shortage. There are MANY restrictions on the work that a 16- or 17-year-old can perform that are in place through the Department of Labor—use of lift equipment being one of them. Most facilities simply don’t want minors doing care.

For BNATP, is there state guidance on nursing assistant role limits regarding the following tasks?
  • Measuring pulse oximetry
    • This is for the CNA II role. A CNA I should not be measuring pulse ox.
  • Switching between oxygen sources (to/from a portable unit)
    • No. This is for the CNA II role. Oxygen is a drug that requires a physician’s prescription which means only a licensed nurse can administer it. This includes changing settings. The nurse supervising the CNA is liable if the CNA transfer a resident from an oxygen concentrator at 2l/min to a portable tank at 3l/min, for example.
  • Applying positive airway pressure devices for sleep apnea
    • No. CNAs cannot perform this, but we are researching whether a CNA II should have this skill.
  • Switching between a standard urinary drainage bag and a leg bag
    • Yes, a CNA can do this as long as they are only manipulating the drainage bag and using enhanced barrier precautions.
For high school students in a full year program, would it be acceptable to do the background check after Christmas Break? Reason is if they struggle and come out of the class, it wouldn't appear as if they were in a program. Also, most are not even 18 so if they did have something on the background check, it would not even show up

Background checks are not required for secondary school students. You should not be doing them at all—regardless of the student’s age

For programs approved for 48 clinical hours, would approval ever be considered for virtual time for hours that go beyond 40? In our dual credit program, we often have many high school students needing clinical make-up hours and are limited in when they can attend, thank you.

Virtual clinicals and lab sessions are not allowed for any reason.

Can you provide guidance regarding clinical group assignment/placement for students. Is the ratio still 8:1 (student to Instructor)? Can you still seek IDPH permission if there are 9 students? Can students be assigned to one floor under the supervision of one Instructor with a split hallway?

There have been times when 9 students have been allowed due to instructor nonavailability, instructors quitting suddenly, cohorts shrinking in size, etc. Email Randy for permission and the reason why you need 9 students

Can CNA students have Clinicals at an Assistant Living Facility?

Yes, but consider the skills they will be using. Some students have a portion of their clinicals in assisted living and the remainder in a hospital or nursing home.

Can a CNA student at an Assisting Living Facility partner with a Healthcare Worker who is not a CNA?

CNA students should not be partnering with anyone other than their clinical instructor.

Has any institution had luck recruiting faculty from a specific source other than job boards, etc.?

I have no information on this. I will post these questions online and if anyone wants to share, they can email Randy.

When we add extra days for snow days at the end of our program, does our end date have to be moved or can we keep the end date the same but have extra make up days added after the end date just in case? - Thank you!

You can keep the end date as it is. Many programs use this additional time to provide a comprehensive review before the certification exam—especially secondary programs with the course running over two semesters

Will the CNA testing begin to reflect the next gen model of testing?

CNA testing is aligned with the NCLEX-PN and the NCLEX-RN. Unless the NCSBN changes the requirements for testing of nursing students, CNA testing will remain the same. I have no idea what the “next gen” model of testing is.

Is there a certain amount of times that a student can repeat the BNATP?

No, a student can retake a BNATP as many times as they can afford.

I'm looking at our cluster score report and trying to improve our scores and FTPR. Can we depend on the Test Item Development Duty Areas to be up to date? Thanks!

Test Item Duty Areas are always up to date. We are, however, exploring an expansion of  the number of test questions to 100 questions which would allow for more questions in some of the duty areas where there are currently only 4-5 questions.

Can you clarify when master schedules are due?

15 days before the start of the class. They can be sent up to 30 days in advance, but no further. It will be rejected. The likelihood of having to revise a schedule sent too far in advance increases the further ahead you schedule it

What documentation for ITIN should we collect from student who does not have an SS card?

A copy of the ITIN card.

In regard to SSN cards and ITIN cards:
  • Will we need to continue copying the original SSN cards of all prospective
    students? I believe that those with ITIN cards will have to be copied, too. Is that correct?
    • SSNs and ITINs have to be copied.
  • What distinguishes an SSN card from an ITIN card?
    • That was/will be answered in my slide presentation. An ITIN is green and white and states “for tax purposes only” on it.
  • Do you know of any facilities that are NOT hiring CNAs that only have an ITIN? What is the likelihood that facilities will not be hiring these CNAs given the current need for CNAs?
    • An ITIN is not an authorization to legally work in the U.S. Any employer who hires someone who is not a U.S. Citizen will be subject to fines and punishment by the Immigrations and Customs Enforcement.
Is there the possibility that Skill 6 Partial Bath, could be replaced with Complete Bath? There is a need for students to know how to give a complete bath thoroughly, correctly, and safely. If a student can give a complete bath, they would be able to perform a partial bath. This would be similar to what was done a number of years ago. “Make an Unoccupied Bed” was eliminated but, “Make an Occupied Bed” remained. that was done a number of years ago.

The skill does not have to be changed. You can always do more than is required. You just cannot do less than is required. If you are having students demonstrate a complete bath, you are in compliance

Is there the possibility of eliminating Skill 21 Measure & Record Height? In my 45 years of practicing as a nurse assistant, nurse, and BNATP instructor, I have never had to obtain a height on a resident.

I have never had a nursing position where I did not record height. Height and weight arepart of BMI calculations upon which drug dosages can be determined

What is the status of eliminating the skill performance testing for recertification?

The legislation has been approved, but it must pass through one more board for its review. That board cannot meet quorum and the legislation is stalled until they can review it. When it passes, it will be in the monthly updates. The new legislation will be in the links on the home page of

I teach a high school class. A few years ago, we did not have the students get background checks, as it was not required for secondary programs. However, because they did not have a background check, their names did not show up on nurse aide registry after they passed the exam. We have done background checks ever since because it was such a huge nightmare when that happened. Is that still the case? We would like to save the students money by not doing a background check, but don’t want to go through that again

Background checks have nothing to do with certification not showing on the registry. You are not required to do background checks, but you ARE required to make sure each student has a profile created in the registry and that you are entering training dates. If you need instructions, please email me. I will send you the training document.

Will the 21 Performance Skills Videos be updated/revised? There are a number of videos that are at least 25+ years old. I notice that there are a number of skills that could be enhanced:

We will begin work on creating new videos.

Hi, my question would be- can we add to skills that student needs to be signed off - Changing incontinence brief (present textbook only has written form, there is no video) Thank you

There are 21 mandated skills based on what industry stated were the only
skills that a CNA does every day, all day, in which they must be proficient. You can add many, many skills. We only test on the 21 skills, but there are over 200 skills that CNAs actually learn

Facility reimbursement question:

Reimbursement for CNA training through HFS (Department of Healthcare and Family Services): TITLE89: SECTION 140.539. Facilities should go through their HFS contact for Medicaid. Facilities must reimburse all or a portion of a CNA’s training within the first year after certification but can receive
reimbursement of these payments through HFS.

If a student fails/leaves the program, do I have to remove them from the registry?

You cannot delete a registry entry. Just enter the last date they actually attended classes as the end training date.

With the new clinical orientation time—do we need this time for each clinical location?

There should be some kind of orientation to each facility. Where is the pre- and post-conference held? Where are the supplies? What unit will the students be using?

In clinical, can students be split between two units if on the same floor?


Is it possible to update the Program Coordinator Guide with the latest updates to have information in one place?

The PCG was just updated this year.

Is there a class size limit for high school level?

For theory, no. All the instructor to student ratios in the lab and clinicals are the same for all BNATPs.

How does the requirement for four hours of Alzheimer’s CEUs apply to instructors who teach in an accredited entry level RN and LPN program?

State in the body of the email when applying for an instructor code that they are teaching in a nursing program and do not need the CEUs to teach in a BNATP.

Is there a website to check for nursing home tag status for clinical ability?

Unfortunately, no. Just email with the facility name and location.

Can students do theory and test for CPR online and do check offs during class?

Yes. The major CPR instructional providers already have an online component. Please note that students who already possess a BLS/healthcare provider CPR certification can be given four hours of credit. They do not have to attend class during CPR instruction and certification. If you are providing 80 hours of theory/lab, you can provide 76 hours in these cases. If all of your students always have CPR certification before classes start, state on page one of the master schedule that all students are certified and have been given four hours of credit. We will expect 76 hours of theory in these cases.