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State Issues DAL Reminding Providers of Expectations Regarding Dually Certified Home Care Aides

(April 29, 2025) The Department of Health (DOH) issued a Dear Administrator Letter (DAL) reminding Home and Community-Based Services (HCBS) providers of expectations for home care aides who are dually certified as Home Health Aides (HHAs) and Personal Care Aides (PCAs) listed in the Home Care Registry (HCR).

  • PCA certificates do not lapse for aides who completed the PCA certification before and after 2009 and who are listed in the HCR.
  • For HHA certificates acquired before 2009, and the aide is listed in the HCR, the certificates are valid if the aide has completed an approved training program or is employed by a qualifying agency within the last 24 consecutive months.
  • HHAs with certificates that have lapsed (i.e., due to lack of employment as an HHA within the last 24 consecutive months in an approved agency) may only renew their certificate by participating in an approved HHA training program. The aide is eligible to take the competency evaluation program in lieu of the standardized training. If the aide does not successfully demonstrate competency, they must undergo the full training curriculum to be recertified as an HHA.
  • If the aide is dually certified and listed in the HCR, and their HHA certification has lapsed, the aide may work under their PCA certificate provided that their employment is within the scope of practice of a PCA.
    • It is important to note that if an aide chooses not to renew their HHA certificate and works solely as a PCA, the in-service requirement for HHA is moot. Instead, the aide will be required to meet the PCA in-service requirement.
  • If the aide acquired their HHA or PCA certificate prior to 2009, and they are not listed in the HCR, the agency must direct the aide to attend an approved training program.

Questions regarding the DAL may be submitted via email to hhatp@health.ny.gov or pcatp@health.ny.gov, as applicable to the training program type.

Contact: Meg Everett, meverett@leadingageny.org, 518-867-8871