Skilled Nursing Facilities & the Four-Month Grace Period

The question arises out of the situation when one facility does not know exactly how long another facility used a nurse aide. So the question becomes, What sort of system does the Registry require a facility to have in order to “track” how long other facilities used a nurse aide?

Each long-term care facility is responsible for checking the prior nurse aide service history of every individual it plans to use as a nurse aide. If this check reveals that another long-term care provider used an individual previously as a nurse aide, the facility should question the individual about the prior service. A facility must count any prior service as a nurse aide against the four month grace period. Training and testing, including the clinical portions of the training program, generally do not count toward the four month limit. However, if a facility chooses to use an individual as a nurse aide after he or she has completed the first sixteen hours of training, then the Registry would start calculating the four month grace period when the facility first uses the individual as a nurse aide.

The Registry would consider a facility to be in compliance with the aforementioned requirement if the facility has adequate documentation showing that it made an inquiry about previous service. Such documentation may include, but would not be limited to, a statement from the individual or prior facility-employer showing the length of prior service as a nurse aide with any facility or stating that the individual had no prior service as a nurse aide.