CMS Pub. 100-11, ch. 9, § 20.4

The PACE organization must provide ongoing training to maintain and improve the skills

and knowledge of each employee and contracted staff member with respect to their

specific duties in order to ensure that PACE participants receive the highest quality care

possible. A PACE organization has the ultimate responsibility for all care provided to

their participants and, therefore, it is in the best interest of PACE participants and the

PACE organization that they provide training specific to their participant population.

Ongoing in-service training for all staff will ensure that skills remain current and any

detrimental practices are caught and rectified as early as possible.

Annual training must be related to specific positions which include relevant topics.

Training needs to be staggered throughout the year to enable all staff to participate. The

training program needs to describe plans for in-service training, the methods of teaching

including handouts, pre and post test, if applicable, and the person/position conducting

the training. Some PACE organizations may have the ability to use the health care facility

to which they are related or they may use an outside agency for training purposes.

OSHA training must be provided on hire and is required annually, [29 CFR

1910.1030(g)(2)] by a qualified trainer. The employee cannot be given just a manual,

pamphlet or policy to read. This training must be given in an interactive session with a

trainer present.

[42 CFR §§ 460.66(a); 460.71]