Wisconsin's Feeding Assistant Training Program
PDF Version for DQA 09-006
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Wisconsin's Feeding Assistant Training Program Requirements
DQA Memo 08-026 announced the approval of the revisions to Chapter DHS
129, Wisconsin Administrative Code. The purpose of this memo is to provide
direction and guidance regarding the actual implementation of the changes
that affected the training of feeding assistants as of December 1, 2008. The
December 1, 2008 version of ch. DHS 129 is available at http://www.legis.state.wi.us/rsb/code/dhs/dhs129.pdf.
This memo contains important information on the following topics:
- Purpose of the Feeding Assistant;
- Health Professional Requirements;
- Standardized Feeding Assistant Curriculum;
- Annual In-service for Feeding Assistants;
- Caregiver Misconduct Reporting Requirements;
- Survey Process;
- Training Program Suspension and Termination; and
- Feeding Assistant Program Resources.
On September 26, 2003, the Centers for Medicare and Medicaid Services
(CMS) published the final rule for paid feeding assistants. These federal
regulations may be accessed at: http://www.access.gpo.gov/nara/cfr/waisidx_03/42cfr483_03.html.
(Refer to 42 CFR 483.35 and 483.160.) Providing assistance with eating and
drinking was considered a direct nursing related service that could only be
performed by a nurse aide or other health care professional who was
qualified to perform this function.
CMS does not consider assisting a resident who has no feeding
complications with eating or drinking as "nursing or
nursing-related" duties. With this federal rule revision, long term
care facilities are allowed to employ certain trained individuals to assist
residents with eating and drinking.
Long term care facilities that want to employ individuals to assist a
resident who has no feeding complications with eating or drinking must meet
the requirements established in ch. DHS 129, Subchapter III - Feeding
Assistants, Wisconsin Administrative Code. This memorandum explains the
requirements and provides guidance.
Purpose of the Feeding Assistant
The purpose of the feeding assistant is to supplement nurse aides and
licensed nursing staff. Section 42 CFR 483.35(h)(2) requires feeding
assistants to be supervised by RNs and LPNs. The requirement to complete a
State-approved training program for feeding assistants under 42 CFR
483.75(q) does not, therefore, apply to LPNs, RNs, or nurse practitioners.
"Paid feeding assistant" means a person who meets the
requirements specified in 42 CFR 483.35(h)(2) and who is paid by the
facility to assist residents who have no complicated feeding problems with
the activities of eating and drinking. Complicated feeding problems include,
but are not limited to: difficulty swallowing, recurrent lung aspirations,
and tube or parenteral/IV feedings.
A feeding assistant is not permitted to provide any other nursing or
nursing related service. Paid feeding assistants must be at least 16 years
old. Facilities are prohibited from counting paid feeding assistants toward
their minimum nursing-related staff requirements.
Health Professional Requirements
A health professional working at the facility may not feed residents
unless the health professional has received appropriate training relating to
feeding, either in conjunction with the education for his or her
professional licensure or by successfully completing State-approved training
for a paid feeding assistant. Section 42 CFR 483.75(q) specifies the
training requirements for feeding assistants.
In comments published with the final regulations, CMS stated facilities
may consult a speech-language pathologist, i.e., a speech therapist, when a
resident is suspected to have, or is at risk for having, swallowing
difficulties. This response implies that a speech therapist/speech-language
pathologist would have received appropriate training relating to feeding in
conjunction with the education for the therapist's professional licensure.
If the speech therapist's or speech-language pathologist's training
included feeding and swallowing issues as part of their training for
licensure, then this individual would be able to assist appropriate
residents with the activities of eating and drinking without first
completing a feeding assistant training program. The same would be true of
physicians, physician assistants, physical or occupational therapists,
physical or occupational therapy assistants, and licensed or certified
They may assist residents who have no feeding complications with the
activities of eating and drinking without first completing a feeding
assistant training program, if the curriculum they completed for their
health professional credential included training comparable to the training
for a feeding assistant.
If, however, the curriculum for their health professional credential did
not include training comparable to the training for a feeding assistant,
they would need to successfully complete the training for a paid feeding
assistant before feeding residents.
Volunteers and family members are also still allowed to assist residents
with feeding and drinking. Facilities must make a good faith effort to
evaluate risks to individual residents and assist volunteers and family
members with appropriate items and techniques to minimize any risk to a
Standardized Feeding Assistant Curriculum
Feeding assistant training programs must use a training curriculum which
has been approved by the Department and determined to comply with the
federal requirements. Entities are allowed to choose one of the following
approved, standardized curriculum models:
- Assisted Dining: The Role and Skills of Feeding Assistants, by the
American Health Care Association
- Assisting with Nutrition and Hydration in Long-Term Care, by Hartman
- Eating Matters-A Training Manual for Feeding Assistants, by the
American Dietetic Association
- Paid Feeding Assistant Training Program, by the Wisconsin Department
of Health and Family Services
Training programs must select one of the model curriculums listed above
to provide feeding assistant students instruction on the federally mandated
topics outlined in ch. DHS 129.11(1)(a-h).
Annual In-service for Feeding Assistants
Feeding assistants must receive an annual in-service training on relevant
feeding assistant topics. Any topic area included in the curriculum is
In addition, feeding assistants must be evaluated on a yearly basis to
document that their skill performance and feeding competence is
Caregiver Misconduct Reporting Requirements
Wisconsin's Caregiver Law, implemented in October 1998, requires all DQA-regulated
entities to report allegations of misconduct (abuse or neglect of a client
or misappropriation of a client's property) regarding any caregiver who is
an employee of or contractor with the facility and who has regular, direct
contact with clients.
A feeding assistant does meet Wisconsin's definition of a caregiver, and
allegations involving a feeding assistant are subject to the caregiver
misconduct reporting requirements. See http://www.dhs.wisconsin.gov/caregiver/contacts/Complaints.htm
for more information. The name of any noncredentialed caregiver, including a
feeding assistant. with a substantiated finding of misconduct will be
entered on the Wisconsin Caregiver Misconduct Registry.
DQA's current survey process provides oversight of facilities' use of
feeding assistant requirements. During surveys of nursing homes and ICFs/MR,
surveyors may observe the meal or snack service to note if any of the
residents receiving assistance from a feeding assistant are showing signs of
difficulty eating or drinking. If such difficulty is observed, surveyors
investigate to determine if this is an unusual occurrence or a chronic
problem and whether the feeding assistant has successfully completed an
approved feeding assistant training program or has met the grandparenting
The feeding assistant's personnel records must contain a copy of the
approved feeding assistant training or grandparenting certificate. Note:
Single task workers approved prior to March 12, 2004 were allowed to
continue as feeding assistants if they completed a training course that met
the federal minimum eight-hour training requirements for a feeding assistant
or were provided training prior to July 31, 2004. An employee who did not
meet the minimum feeding assistant training requirements by July 31, 2004
must have satisfactorily completed a feeding assistant training and
Surveyors will determine if residents being served by a feeding assistant
are persons with no complicated feeding problems. This determination may
include a review of medical charts and discussion with the professional
nursing staff. DQA surveyors may monitor the facility's residents during
feeding, to ensure only the residents included in the approved selected
population are fed or hydrated by the feeding assistants.
A facility may be subject to citation if deficiencies are identified by
the surveyor. The facility is required to retain training and employment
records of feeding assistants, to document the facility's compliance with
program requirements, and to provide a record for surveyors to review. If
the surveyors observe inadequacies in the feeding assistant training
program, that information will be referred to the Dietician Consultant.
Feeding assistant training program complaints that warrant further
investigation will result in an unannounced on-site review.
Training Program Suspension or Termination
Training programs failing to meet their program requirements or operating
under conditions other than those contained in the approved application, may
be issued a notice of suspension, revocation of the feeding assistant
training program approval, or an imposed plan of correction.
Feeding Assistant Program Resources
Please access the website at http://www.dhs.wisconsin.gov/caregiver/FeedingAssistant/FeedingAsts.htm
for complete information.
If you have any questions regarding feeding assistant training, please
If you have any questions regarding feeding assistant survey
requirements, please contact the appropriate Bureau of Nursing Home Resident
Care (BNHRC) Regional Office. See http://www.dhs.wisconsin.gov/rl_DSL/Contacts/reglmap.htm
for contact information.
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