An Earn and Learn program is the establishment of a CNA training program, either facility based, or community based, that allows individuals with no prior experience to start their CNA journey while being employed and compensated by the facility throughout the course of their training. 

Yes, if they are your employees and are paid their hourly wages while they’re in school.

Engaging in a facility based NATP Earn and Learn program means that your facility is NATP accredited by CDPH to train new CNA’s (reflected on your 280A form), granting you the ability to conduct new CNA theory and clinical training at your facility. Students must be hired and compensated by your facility throughout the course of their training. Once the student completes their training program and obtains certification through CDPH, they are qualified to begin working their CNA duties at your SNF. All facility based NATPs are by regulation Earn and Learn.

Engaging in a community based Earn and Learn program involves your facility partnering with a CDPH approved community based NATP (online or brick and mortar) where the community based NATP provides CNA theory and clinical training to the individuals that you hire. Once the CNA successfully completes their training program and obtains certification through CDPH, they are qualified to begin working their CNA duties at your SNF.

Yes, participating in an Alternative Online Earn and Learn program implies that your facility holds CDPH approval as a facility based NATP, but in this arrangement, you partner with a CDPH approved online community based NATP to conduct the theory training, while your facility takes responsibility for the clinical training component.

No, you may partner with a community based NATP to provide the training component if you are not a facility based NATP. They will provide the training for the employees that you’ve hired who are “Earn and Learn” students.

To partner with a facility-based NATP “training hub,” or community-based NATP Earn and Learn Program follow these steps:

1. Submit Required Forms: Submit both the 278C (Facility Declaration of Participation in Approved Training Contract) and 278SC (Option 2 Nurse Assistant Pre-Certification Training Contract) forms to CDPH. These forms reflect your CNA training agreement with your training site, either a regional training hub facility or a community-based NATP. 
2. MOU: It is necessary to formalize the training agreement with an MOU between the training site facility and the facility sending employees to be trained. You can refer to the provided example for reference/use. (see example)
3. Send Forms & the MOU to CDPH: Send all forms via email to CDPH at tpru@cdph.ca.gov. In the email subject line, include the training facility’s name and their training ID number. Use “(F-)” if applicable to facility-based training or “(S-)” if applicable to facilities partnering with a school. (This takes approximately 2 weeks to hear back from CDPH.)
4. After Approval: Once approved by CDPH, facilities that hire students and send them through training following the Earn and Learn Guidelines, qualify for CNAP Earn and Learn Awards. 

By following these steps, you can partner with a “training hub” facility-based Earn and Learn program or a community-based training program (community colleges or specialty schools.) Your facility may potentially qualify for CNAP Earn and Learn awards.

Creating a facility-based NATP to provide training to your facility and other SNFs in your local area is possible. One SNF is approved by CDPH to serve as the NATP (Training SNF), and the Sister or “Other” SNFs send students there to go through their CNA Training.

Here are some factors that would need to be built into the training model.

1. The Training SNF would need to have a CDPH approved NATP.
2. The Sister or “Other” SNFs would need to do the following:
   • Hire Students at the start of training and pay them wages both for time spent training at the Training SNF, and for any hours they spend working at the Sister or “Other” SNF.
   • The Training SNF and the Sister or “Other” SNFs will need to develop a contract that spells out their business relationship (MOU).  This includes payments from Sister or “Other” SNFs to the Training SNF for student tuition.
3. The Sister or “Other” SNFs will each need to submit the following documents to CDPH:
   • CDPH Form 278C indicating that they are contracting with an outside agency to train their CNAs.
   • CDPH Form 278SC, serving as a contract between the Training SNF and the Student SNF.
   • An MOU/Contract spelling out additional details (see example).
4. Students will be employees of the Sister or “Other” SNF, but will be Nurse Assistant students (NA) while they are at the Training SNF.
5. Students may not be counted toward staffing hours by the Training SNF.
6. Students can be counted toward 3.5 staffing requirements by the Sister or “Other” SNF if they do work there utilizing skills that they have been trained on, and signed off on by the NATP Instructor.

One additional area that should be reviewed is ensuring that this training program is exempt from management by the Bureau for Private Postsecondary Education.  There are at least two categories under which they would qualify for exemption.

The Bureau for Private Postsecondary Education (BPPE) is a component of the Department of Consumer Affairs that regulates vocational training schools.  It’s intended to prevent schools from cheating students.  Not all private NATPs need to be governed by BPPE, exempt schools include accredited colleges, non-profit or religious schools, or schools that are very small and charge tuition of less than $2,500 per program. 

All NATPs, whether facility-based or non-facility-based, are required to have their training program approved by CDPH and are required to meet the same standards. The sample application materials presented in the CNAP Webinar on NATP approval apply both to Facility based NATPs and non-facility NATPs.  

For non-facility based NATPs there are pros and cons for being BPPE regulated.  For BPPE regulated schools they are eligible to participate in government workforce development programs. Non-BPPE regulated schools cannot participate in these programs, but are exempt from BPPE Fees ($5,000 initial, 1% of tuition received annually, $5 per student per $1,000 tuition paid for Student Tuition Recovery Fund) and BPPE paperwork (40+ pages of disclosures required prior to enrollment). 

Yes, this is how a facility with a training ban can partner with a training entity and qualify for CNAP Earn & Learn awards: 

Contract with Community-Based NATP – Change of Status 

If your Facility 280A form states: “Hire CNA Only” and you want to train through a Community NATP you can change this status as follows: send an email to: tpru@cdph.ca.gov 

If a facility wishes to change their training status to provide pre-certification training to their uncertified staff through an approved nurse assistant training program (NATP), they will need to: 

1) Request a 280A status change to initiate a new status “NATP Contract with Approved School” 

2) Submit CDPH form 278C and check Option 2 (refer to CDPH form 278C page 2) 

“Skilled Nursing Facility (SNF) or Intermediate Care Facility (ICF) employees who are not eligible to be employed as aan NA may be employed in another role (e.g. activities, dietary, laundry, housekeeping), but cannot work as an NA or in an NA capacity providing direct patient care.”  

3) Submit CDPH form 278SC (contract with NATP provider) 

4) Submit MOU with training entity. 

5) Provide Necessary information. In the body of the email, clearly confirm that you have NO intention of employing NAs, and that no employee that would be in training will work as a NA.  

*Specify that the employee’s job classification will not change to CNA until after they are certified. 

6) Once approved, CDPH will issue an updated CDPH form 280 that reflects “Hire CNA Only” AND “NATP Contract with Approved School”. 

Earn and Learn awards will be issued “after” students have become certified. The awards will be granted for those students after documents and reporting submission to CNAP has been completed (within approximately 3 weeks). Awards are issued after you have provided CNAP with a copy of CNA students I-9’s (substantiating that the student was hired and compensated throughout the course of their training), and their certification verification via https://cvl.cdph.ca.gov/SearchPage.aspx  is submitted and verified. Additionally, the Facility Reporting form reflecting the entire cohort, and the CNA demographic form for each cohort participant must be completed before disbursement (Access to these forms can be found on the MOU).

The facility reporting form and CNA demographic form are for CNAP Earn and Learn partners to report on their cohort status, such as the number of students accepted into your cohort, the number of students that completed the program, the number of students retained after their certification completion, etc... This basic reporting is required by HCAI, our grant funder. The CNA demographic form can be filled out by either you or the individual student to report on demographics, such as race and ethnicity. Access to these forms can be found on the MOU. 

A “Training Hub” for sponsored students is when a parent organization uses one of more of their facilities as a designated training site that sister facilities send their Earn & Learn students to for CNA training. Yes, if your facility sponsors students to undergo CNA training at a sister SNF, you may qualify for Earn and Learn awards, if your facility has applied and is approved as an Earn and Learn participant of CNAP. 

Yes, a facility can engage in both an Earn and Learn program (facility based OR community based) and host clinical rotations for a community NATP. Hosting clinical hours is a separate opportunity for facilities to provide training sites for students enrolled in community NATPs.  

However, CNAP does not provide funds for both E & L and clinical hosting for the same CNA cohort. 

The Local Workforce Development Boards (“LWDBs”) in California do have funds under a program of “On the Job Training” to subsidize wages during a period of learning on the job. Availability and guidelines will vary among LWDBs, so you will need to contact your Local Board for applicable guidelines. CNAP can assist you in connecting with your Local Board. Wage subsidies are related to the costs of training and additional supervision. Levels of wage subsidies will vary but can be up to 50%-70% of wages for a training period, and up to $5000 per worker.

Here is the link to the AFL that explains how to count NAs in the 2.4/3.5 Direct Care Service Hours Per Patient Day: https://www.cdph.ca.gov/Programs/CHCQ/LCP/Pages/AFL-21-11.aspx