
AUTUMN 2024 PEER REVIEWED EXCELLENCE IN NURSE LIFE CARE PLANNING SINCE 2006 VOLUME XXIV ISSUE 4
AANLCP JOURNAL OF NURSE LIFE CARE PLANNING ISSN 1942-4469 10
route, injections (outside of insulin and other diabetes related
injectables), sterile procedures, or any delegation that violates
the NPA regulations (NCSBN, 2019; ANA, 2019).
Skilled nursing task delegation provides an opportunity for
the disabled individuals to reside in the community, rather than
in institutional settings. Additionally, SNT delegation decreases
cost of care because HHA services are less costly than those
provided by an RN. For example, the median 2023 annual
salary of the HHA was $33,530 per year, or $16.12 per hour
(U.S. Bureau of Labor Statistics, 2024). On the other hand,
the median 2023 salary for a registered nurse in the home
healthcare setting was $86,070 per year, or $41.38 per hour
(U.S.Bureau of Labor Statistics, 2024). Albeit cost containment
is an important consideration, safe and efcient performance
of delegated SNTs depends on close and effective PA
supervision by an RN.
Delegation of SNTs-Denition, Principles, and
Scope of Practice
The NCSBN and the ANA (2019) dene SNT delegation as
“transfer of responsibility for the performance of a task from
one individual to another while retaining accountability for
the outcome.” Delegation may be from an advanced practice
nurse (APN) to RN, licensed practical nurse (LPN) or PA;
and from RN to LPN, HHA, or PCA (ANA, 2019). The NPA
mandates licensed nurses to adhere to the 5 principles of safe
delegation, including the “right task, the right circumstance,
the right person, the right direction and communication, and
the right supervision and evaluation” (NSBN, 2019; ANA,
2019). The RN is accountable for selection of delegated SNT,
evaluating HHA qualication and task performance, and
patient-and-task specic training and supervision of the HHA.
Additional training and education expands HHA scope
of practice to include monitoring and reporting patient
condition(s), recognizing and responding to emergencies,
and infection control, among others. On the other hand
the PCA assists patients with activities of daily living (ADL)
and instrumental activities of daily living (IADL), that are
incorporated into HHA’s scope of practice. The AHHA is HHA
with a higher level of education and training that permits
them to carry out more complex skilled nursing tasks under
the supervision of an RN. Aligning HHA’s, AHHA’s, and PCA’s
the scope of practice with the level of care necessary to meet
the disabled individual’s needs will facilitate development
of reasonable, effective, and appropriate recommendations
in the life care plan. If the subject only requires assistance
with ADL or IADL, then a PCA can be used. However, skilled,
or complex care is needed, then HHA, AHHA, LPN, or RN
may need to be recommended. The NLCP/LCP must be
knowledgeable in the state NPA, and collaborate with the
healthcare providers, the disabled individual, the family, and
other pertinent stakeholders to identify the level of care (RN,
LPN, HHA, AHHA, PCA) that needs to be incorporated into a
life care plan.
HHA/AHHA Scope of Practice, Certication,
and Level of Care
Whereas the HHA/AHHA scope of practice is governed
by state statues, there are some federal requirements
that establish minimum level of education and training.
“The Federal Code of Regulations Title 42-Public Health
(§ 484.36)-Conditions for participation:Home Health Aide,”
mandates “classroom and supervised practical training at
least 75 hours, with at least 16 hours devoted to supervised
practical training” (Code of Federal Regulations, 2010). The
scope of practice of HHA includes provision of ADL, IADL,
infection control, safety, measurement of vital signs, identifying
emergencies, competency in emergency measures, monitoring
patient status, and reporting changes to an RN.
The scope of practice of AHHA includes all of the HHA
functions in addition of specialized SNTs where AHHA
demonstrated prociency. In NYS, “Chapter 471 of the
Laws of 2016 Article 139 of the Education Law (the Nurse
Practice Act),” was amended in order to allow AHHA to
perform “advanced tasks with appropriate training and upon
assignment by registered nurses and under supervision by
such nurses” (NYS DOH, 2021). The AHHA is permitted to
administer medications, including insulin or other diabetic
injections, “injections of low molecular weight heparin, and
pre-lled auto injections of naloxone and epinephrine”(NYS
DOH, 2021). However, the AHHA is not allowed to inject other
medications, to perform sterile procedures and invasive wound
care, and to manage central line infusions, or site care (NYS
DOH, 2021).
HHA, AHHA, PCA Supervision Frequency
Safe SNTs delegation depends on RN’s adherence to the
NPA guidelines in planning and on-going HHA supervision
and performance monitoring (NSBN, 2019; ANA, 2019).
Projecting the frequency of RN supervisory visits is an
important consideration in the life care plan. The NLCP/
LCP need to be familiar with state NPA and the Department
of Health (DOH) regulations regarding HHA supervision.
For example, the NYS Education Department Ofce of the
Professions in a “Memorandum of Understanding for Nursing
Supervision for Mental Retardation and Developmental
Disabilities recommends annual nursing visits for skilled care
evaluation. In contrast, chapter 471 of the Laws of 2016 Article
139 of the Education Law mandates that RN must make
supervisory HHA and AHHA visits every two weeks. By the
same token, California (Cal. Code Regs. Tit. 22, § 74709-Home
Health Aide/Personal Care Services Supervision) requires
HHA supervision every 14 days if skilled nursing services are
provided. If an RN delegates HHA supervision to an LPN, then
the RN must visit every 3 months. Conversely, in Florida, the
HHA must be supervised every two weeks for skilled nursing
services, and every 60 days if non-skilled, PCA services are
provided (Florida Administrative Code 59A-8.0095 Personnel).