Hiring complianceRead at source, 30 September 2026
HHA Training Rules for Home Care Agencies, by State
Medicare-certified home health agencies must use aides who meet 42 CFR 484.80. Where training is the route, it is at least 75 hours, with at least 16 classroom hours before at least 16 hours of supervised practical training; every aide must pass a competency evaluation and get 12 hours of in-service training a year. Many states require more. In state rules read 30 September 2026, Alaska, California, the District of Columbia, Illinois, Kansas, Maine, Maryland, New Jersey and Rhode Island set a higher bar, most by requiring CNA certification first. The table cites each.
The federal floor: 42 CFR 484.80
The rule every Medicare-certified home health agency shares is the home health aide condition of participation, 42 CFR 484.80. It opens bluntly: all home health aide services "must be provided by individuals who meet the personnel requirements" of the section. An aide qualifies in one of four ways under 484.80(a)(1):
- A training and competency evaluation program that meets the standards in (b) and (c).
- A competency evaluation program on its own, meeting (c).
- A state-approved nurse aide training and competency evaluation program under 42 CFR 483.151 to 483.154, with the person currently listed in good standing on the state nurse aide registry.
- A state licensure program that meets the standards in (b) and (c).
Where training applies, the numbers are fixed. Classroom and supervised practical training "must total at least 75 hours," and "a minimum of 16 hours of classroom training must precede a minimum of 16 hours of supervised practical training as part of the 75 hours." Practical hours are supervised by an RN, or an LPN working under one.
| Requirement | What the rule says | Paragraph |
|---|---|---|
| Training | At least 75 hours of classroom and supervised practical training; at least 16 classroom hours before at least 16 supervised practical hours | (b)(1)–(2) |
| Competency evaluation | Required before the aide furnishes services; performed by an RN; five skill areas must be observed with a patient or pseudo-patient | (c) |
| In-service | At least 12 hours in each 12-month period, supervised by an RN | (d) |
| Instructors | An RN with at least 2 years of nursing experience, at least 1 of them in home health care, or others under that RN’s general supervision | (e) |
| Lapse | 24 consecutive months without paid aide services means completing another qualifying program before working again | (a)(2) |
One detail matters for hiring: 484.80(f) bars an agency from running its own training or competency program if, within the previous two years, it was out of compliance with the aide standards, let an unqualified person work as an aide, or drew certain sanctions, such as a civil monetary penalty of $5,000 or more.
State table: training hours, registry and certification, by state
Among the nine states in the table below, the most common way to go beyond the federal floor is not a bigger HHA course: it is requiring the aide to be a certified nursing assistant first. The table lists the states where we confirmed a requirement above 75 hours in the state’s own text on 30 September 2026. The federal rule still applies on top for a Medicare-certified agency.
| State | What the state requires of a home health aide | Training hours | Registry or certification | Source |
|---|---|---|---|---|
| Alaska | Must be a Board-certified nurse aide | CNA program of at least 140 hours: 60 didactic, 80 supervised skills and clinical | Alaska certified nurse aide registry | 7 AAC 12.519; 12 AAC 44.835(c) |
| California | State HHA certification | 120-hour CDPH-approved program, or an active CNA certificate plus a 40-hour CDPH-approved program | HHA certificate issued by the California Department of Public Health | CDPH, Home Health Aide certification; Health and Safety Code 1725–1742 |
| District of Columbia | Board-approved HHA training program and certification exam | Board curriculum: 65 classroom, 20 lab, 40 clinical | Certified by the DC Board of Nursing; 24 hours of in-service or continuing education per renewal period | DC Board of Nursing HHA curriculum; 17 DCMR chapter 93 |
| Illinois | On the Health Care Worker Registry, a Part 395 program, or a listed equivalency | Basic nursing assistant program of at least 120 hours: 62 theory, 18 lab, 40 clinical | Health Care Worker Registry check before hire | 77 Ill. Adm. Code 245.70; 77 Ill. Adm. Code 395.150 |
| Kansas | Kansas-certified nurse aide, 20-hour HHA course and state test | Nurse aide course (the rule refers to 90 hours) plus 20 hours | Certified by KDADS and listed on the public nurse aide registry | K.A.R. 28-51-113 |
| Maine | Defined as a CNA who meets state rules and 42 CFR 484 | Approved 130-hour CNA course | Maine CNA and Direct Care Worker Registry | 10-144 CMR ch. 119, §1(20); Maine DHHS CNA Registry |
| Maryland | CNA plus an HHA competency evaluation | CNA program of at least 100 hours: 60 didactic and lab, 40 supervised clinical | Maryland Board of Nursing; 12 hours of in-service a year to keep HHA status | COMAR 10.39.01.09B; COMAR 10.39.02.06A |
| New Jersey | Certified homemaker-home health aide | At least 76 hours: 60 classroom, 16 clinical | Certified by the New Jersey Board of Nursing | N.J.A.C. 13:37-14.4, Board training manual |
| Rhode Island | Must be a registered nursing assistant | At least 120 clock hours, including at least 40 hours of practical training | Nursing assistant registration, Rhode Island Department of Health | 216-RICR-40-10-17; 216-RICR-40-05-22, §22.7.1 |
States we checked that do not set a home health aide training requirement above the federal 75 hours:
| State | What the state requires | Registry or certification | Source |
|---|---|---|---|
| New York | State-approved HHA training program: at least 75 hours, including at least 59 classroom and 16 supervised practical | Program run under the state Department of Health | NYSDOH, Guide to Operation of a Home Health Aide Training Program |
| Wisconsin | A home health aide must be on the state registry; nurse aide programs must include at least 75 hours, at least 16 of them clinical | Wisconsin nurse aide registry | Wis. Admin. Code DHS 133.02(4); DHS 129.07 |
| Florida | State rule: at least 40 hours of training, or passing AHCA’s home health aide competency test, before an aide provides services; a Medicare- or Medicaid-certified agency also applies 42 CFR 484 | A currently certified Florida CNA may work as a home health aide | Fla. Admin. Code r. 59A-8.0095(5) (effective 31 May 2026) |
Compilations drift. PHI’s state table lists Wisconsin at 120 hours, Maine at 180 and Rhode Island at 100; the state texts we read today say 75, 130 and 120. PHI lists eight more states above 75 hours that we could not confirm in state text today: Hawaii, Idaho, Montana, New Hampshire, Utah, Vermont, Washington and Wyoming. Elsewhere, treat 75 hours as the federal floor and confirm state rules with your licensing agency. If you hire across a state line, the CNA reciprocity rules decide how fast an out-of-state aide gets onto your registry.
This is general information, not legal advice — confirm with counsel or your state agency before you build a training program or set a hiring requirement.
Private-duty and non-medical home care vs Medicare-certified agencies
42 CFR 484.80 is a Medicare condition of participation. It binds home health agencies that participate in Medicare. A non-medical agency billing clients privately for companionship, homemaking and personal care is outside it; any training rule comes from the state.
Florida shows the two tiers side by side: its home health agency rule, 59A-8.0095(5), requires at least 40 hours of training, or passing the state’s competency test, before an aide works for any licensed agency, while an aide at a Medicare- or Medicaid-certified agency must also meet the federal 75-hour standard. Washington regulates non-medical home care separately: long-term care workers must complete 75 hours of training through a program approved by the Department of Social and Health Services and pass the home care aide certification exam (chapter 18.88B RCW, Washington DOH).
A mixed agency should decide per job which rule governs: a caregiver hired for private-pay visits cannot be assigned to a Medicare home health patient as an aide until they meet 484.80. Write the posting to match — the home health aide job description should name the credential, and a caregiver posting should not imply it.
Hiring implication: recruit trained aides or train in-house
Every agency ends up running some mix of two pipelines. Recruit trained means advertising for people who already qualify: CNAs in good standing on your state registry, and aides who finished a program and have worked in the last 24 months. Train in-house means advertising to caregivers without the credential and putting them through a program you run or sponsor. The pool is larger; the cost is the program — an RN instructor who meets 484.80(e), classroom and practical time, paid trainee hours — plus the risk that 484.80(f) removes the option after a bad survey.
Boostpoint does not report home health aides separately in its benchmark. The nearest role family is Caregiver / home care; the CNA / nursing assistant family is the right comparison for the recruit-trained pipeline in states where the aide must be a CNA.
| Role family | Median | Middle 50% | Apply rate | Campaigns |
|---|---|---|---|---|
| Caregiver / home care | $3.76 | $2.99 – $5.83 | 31% | 34 |
| CNA / nursing assistant | $7.72 | $6.18 – $12.06 | 18% | 32 |
In Boostpoint’s 2026 Social Job Advertising Benchmark, the Caregiver / home care median is $3.76 per applicant and the CNA / nursing assistant median is $7.72. Cost per applicant is not cost per hire: an untrained applicant still has to finish the course and pass the evaluation. The full budget math is on home care agency recruiting.
Where HHA training fits in your hiring funnel
- The ad names the pipeline. A recruit-trained ad says the credential is required and names it the way your state does (CNA, certified HHA, registered nursing assistant). A train-in-house ad leads with paid training and the certificate the aide leaves with.
- One knockout question per form. For the credential ad: “Do you hold a current CNA or home health aide certificate in this state?” For the training ad, ask about availability for the class schedule instead.
- Verify after the application, before the first visit. Registry check and competency evaluation sit between offer and first patient; the CNA verification page covers the registry step.
- Book the in-service. Schedule the 12 yearly hours under 484.80(d) at hire.
The channel side of both pipelines is on home health aide recruiting.
Frequently asked questions
How many training hours does a home health aide need?
Under 42 CFR 484.80, an aide at a Medicare-certified home health agency needs at least 75 hours of classroom and supervised practical training, including at least 16 classroom hours before at least 16 supervised practical hours, plus a competency evaluation. An aide can also qualify through a competency evaluation alone or state nurse aide certification in good standing. Several states require more.
Which states require more than 75 hours of HHA training?
Of the state rules we read on 30 September 2026: Alaska (140-hour CNA program), California (120 hours, or CNA plus 40), the District of Columbia (125-hour curriculum), Illinois (120-hour nursing assistant program), Kansas (CNA plus a 20-hour HHA course), Maine (130-hour CNA course), Maryland (100-hour CNA program), New Jersey (76 hours) and Rhode Island (120 hours).
Can a CNA work as a home health aide?
Usually, yes. Federal rule 42 CFR 484.80(a)(1)(iii) accepts a state-approved nurse aide training and competency evaluation program if the person is currently in good standing on the state nurse aide registry. Some states add a step: Kansas requires a 20-hour HHA course and state test, Maryland an HHA competency evaluation, and California a 40-hour program for CNAs.
Do non-medical caregivers need HHA training?
Not under federal law. 42 CFR 484.80 applies to home health agencies that participate in Medicare. Non-medical home care is regulated, if at all, by the state: Florida sets 40 hours, or a state competency test, for aides at licensed agencies that are not Medicare-certified, and Washington requires 75 hours plus a certification exam for home care aides.
How much in-service training do home health aides need each year?
At least 12 hours in each 12-month period under 42 CFR 484.80(d), supervised by a registered nurse. It may happen during patient care. Maryland ties HHA status to 12 hours a year, and the District of Columbia counts 24 hours per renewal period.
Fill both aide pipelines
Boostpoint turns your aide and caregiver openings into Facebook and Instagram job ads, builds and optimizes the campaigns, and sends applicants into your ATS with automated text follow-up, so a training cohort or a credentialed hire starts from a full list. For what it costs, see pricing.
Book a DemoSources: 42 CFR 484.80 (eCFR); the state regulations and agency pages linked in each table row; Boostpoint 2026 Social Job Advertising Benchmark. General information, not legal advice. Last verified 30 September 2026. Read at source 30 September 2026.