A competency evaluation on file for every hospice aide
In 2025, hospice surveyors cited aide competency evaluations more than any other staff-file item. Personnel Ledger keeps each aide's evaluation, the registered nurse who did it and the signed skills checklist together, and shows any aide who is still due.
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Built from the federal hospice aide rule, CMS surveyor guidance and CMS survey reports. General information, not legal advice. Confirm your specifics with your state and your accreditor.
An RN, every subject, and five skills seen in practice
The evaluation covers each subject in the federal aide training curriculum, from communication skills to range of motion and positioning.
42 CFR §418.76(c)(1)Observed with a patient or a pseudo-patient: communication; temperature, pulse and respiration; personal hygiene and grooming; safe transfer and ambulation; and range of motion and positioning. The rest may be written, oral or observed.
42 CFR §418.76(c)(1)A registered nurse performs the evaluation, in consultation with other skilled professionals as appropriate.
42 CFR §418.76(c)(3)An aide is not considered competent in any task rated unsatisfactory, and may not do that task without direct RN supervision until retrained and evaluated again. An aide rated unsatisfactory in more than one required area has not passed the evaluation (42 CFR §418.76(c)(4)).
The evaluation has to come before the aide furnishes hospice aide services. If it was done somewhere else, CMS surveyor guidance expects documentation from the aide or the training organization in the file. An aide who goes 24 consecutive months without paid aide work is no longer considered to have completed the program, and has to qualify again (42 CFR §418.76(a)(2)).
The staff-file item cited most in 2025
By our count of CMS survey reports, 204 of the 2,031 hospice standard surveys in 2025 that found any deficiency cited at least one aide competency tag (L0615 to L0619). Most of those citations came from accrediting organizations.
Source: our count of CMS QCOR hospice survey reports (Form CMS-2567), CY2024 and CY2025 standard surveys with at least one finding, state agencies and accreditors combined.
Skills not shown as observed
The most common wording: no evidence in the personnel file that a listed skill was performed by the aide with a patient, followed by the skills that were missing.
One line for several tasks
A checklist that read "Bath: sponge or tub or shower" was cited because it did not show each bath type was evaluated.
Subjects never evaluated
Files where whole subject areas from the curriculum had no result at all.
A self-assessment instead of an RN
An aide rating their own skills, with no registered nurse observing them, is not a competency evaluation.
One evaluation per aide, with its proof attached
On the aide's file
Record the date, the evaluating registered nurse and the result, and attach the signed skills checklist to that record.
Due before care
Set the requirement to come due a set number of days after hire, so a new aide shows as due from day one instead of surfacing at an audit.
Every aide counted
It applies to the aide role, so per-diem aides and aides under arrangement are in scope the moment they are added.
History kept
When an aide is evaluated again, the new record goes on top and the earlier one stays in the file.
The skill, never the patient
The record holds the aide, the nurse, the date and the result. There is no field for the patient.
Write the skills checklist the way it will be checked
Personnel Ledger stores your checklist; it does not write it for you. These habits come straight from the 2025 findings above.
One line per task
Bed bath, sponge bath, tub bath and shower each on their own line, and the same for shampoo and nail care. A combined "or" line was cited.
Observed skills marked
Show which subjects the RN watched the aide perform with a patient or a pseudo-patient, and which were tested another way.
The RN named and dated
The evaluating nurse's name, credential and the date, so the file shows who did it and when.
An evaluation is only as good as the license behind it: keep each RN's license current with hospice license tracking.
Aide competency evaluations, answered
Who can perform a hospice aide competency evaluation?
A registered nurse, in consultation with other skilled professionals as appropriate (42 CFR §418.76(c)(3)). A licensed practical or vocational nurse cannot stand in for the RN.
Which skills must be observed rather than tested on paper?
Communication skills; reading and recording temperature, pulse and respiration; personal hygiene and grooming; safe transfer and ambulation; and range of motion and positioning. These are observed with a patient or a pseudo-patient. The other subject areas may be evaluated by written or oral examination, or by observation (42 CFR §418.76(c)(1)).
What happens if an aide is rated unsatisfactory on a skill?
The aide may not perform that task without direct supervision by a registered nurse until retrained and evaluated again. An unsatisfactory rating in more than one required area means the aide has not passed the evaluation (42 CFR §418.76(c)(4)).
Does an aide with a state certification still need an evaluation on file?
The rule lets a person furnish hospice aide services only after completing a competency evaluation as the section describes, and 2025 accreditor findings cited aide files with no evaluation in them. Keeping a documented evaluation for every aide is the safer reading. Confirm how your accreditor reads it.
Do aides under arrangement need a competency evaluation?
Yes. CMS surveyor guidance says aides furnished under arrangement must also have their competency checked, so their files need the same evidence as your employees'. See contracted staff files.
When does an aide need to be evaluated again?
When an aide has gone 24 consecutive months without paid aide services, the earlier training no longer counts and the aide must qualify again (42 CFR §418.76(a)(2)). An aide is also re-evaluated when a concern about a skill is verified by the supervising RN.
This page is general information, not legal advice. Hospice aide requirements come from federal regulation, your state's law and your accreditor, and they change. Some states add their own aide credentials; see hospice staff requirements by state.
Know every aide was evaluated before a surveyor asks
Personnel Ledger keeps each aide's evaluation, the evaluating RN and the signed checklist together. Start a free 45-day trial and add your aides today.