Department of Health and Human Services 


OFFICE OF 

INSPECTOR GENERAL 

NURSE AIDE REGISTRIES: 


STATE COMPLIANCE AND 


PRACTICES


Inspector General 

February 2005 

OEI-07-03-00380 
Office of Inspector General 
 http://oig.hhs.gov 

The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, 

as amended, is to protect the integrity of the Department of Health and Human Services 

(HHS) programs, as well as the health and welfare of beneficiaries served by those 

programs. This statutory mission is carried out through a nationwide network of audits, 

investigations, and inspections conducted by the following operating components: 

Office of Audit Services 

The OIG’s Office of Audit Services (OAS) provides all auditing services for HHS, either by 

conducting audits with its own audit resources or by overseeing audit work done by others. 

Audits examine the performance of HHS programs and/or its grantees and contractors 

in carrying out their respective responsibilities and are intended to provide independent 

assessments of HHS programs and operations in order to reduce waste, abuse, and 

mismanagement and to promote economy and efficiency throughout the department. 

Office of Evaluation and Inspections 

The OIG’s Office of Evaluation and Inspections (OEI) conducts short-term management 

and program evaluations (called inspections) that focus on issues of concern to the 

department, the Congress, and the public. The findings and recommendations contained 

in the inspections reports generate rapid, accurate, and up-to-date information on the 

efficiency, vulnerability, and effectiveness of departmental programs. The OEI also 

oversees State Medicaid fraud control units, which investigate and prosecute fraud and 

patient abuse in the Medicaid program. 

Office of Investiga ions t

The OIG’s Office of Investigations (OI) conducts criminal, civil, and administrative 

investigations of allegations of wrongdoing in HHS programs or to HHS beneficiaries 

and of unjust enrichment by providers. The investigative efforts of OI lead to criminal 

convictions, administrative sanctions, or civil monetary penalties. 

Office of Counsel to the Inspector General 

The Office of Counsel to the Inspector General (OCIG) provides general legal services to 

OIG, rendering advice and opinions on HHS programs and operations and providing all 

legal support in OIG’s internal operations. The OCIG imposes program exclusions and 

civil monetary penalties on health care providers and litigates those actions within the 

department. The OCIG also represents OIG in the global settlement of cases arising 

under the Civil False Claims Act, develops and monitors corporate integrity agreements, 

develops compliance program guidances, renders advisory opinions on OIG sanctions to 

the health care community, and issues fraud alerts and other industry guidance. 
INTRODUCTION ∆ EXECUTIVE SUMMARY 

OBJECTIVE 

To determine State compliance with Federal regulations for 

(1) updating the nurse aide registry records of nurse aides who had 

substantiated findings of abuse, neglect, or misappropriation of 

property, (2) removing the records of nurse aides who had not performed 

nursing or nursing-related services for 24 consecutive months, and (3) to 

review State nurse aide registry practices. 

BACKGROUND 

The Omnibus Budget Reconciliation Act of 1987 contained provisions 

designed to assure delivery of quality care to long-term care facility 

residents. Federal regulations (42 CFR § 483.156) require each State to 

establish and maintain a registry of individuals who have completed 

training and who the State finds to be competent to function as nurse 

aides. Nurse aide registries also must include information on any 

substantiated finding of abuse, neglect, or misappropriation of property 

made by the State survey agency related to an individual. 

Used properly, State nurse aide registries prevent unemployable 

individuals from being employed in long-term care facilities. Federal 

regulations require that States update the nurse aide registry records of 

nurse aides with a substantiated finding within 10 working days of 

substantiating that finding. States also must remove from the registry 

the records of nurse aides who have not performed nursing or 

nursing-related services for a period of 24 consecutive months, unless 

the records include substantiated findings. Those records must remain 

on the registry indefinitely, except under specific circumstances, such as 

notification of the death of the individual. 

FINDINGS 

Some States failed to update registries with substantiated adverse 

findings. 

At least 24 of the 38 States that we analyzed in detail did not meet 

Federal regulations for updating registry records of nurse aides with 

substantiated findings within 10 working days. Records of 1 in 4 nurse 

aides (450/1,978) with recent substantiated findings were not updated 

on the appropriate State registry 10 working days after the last possible 

substantiation date in our review period. Of the 450 nurse aide records 

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EXECUTIVE SUMMARY

not updated, 236 still were not updated on the appropriate nurse aide 

registry 3 months after our initial verification. 

Over half of State survey respondents reported failure to remove 

records of inactive nurse aides from registries; some individuals 

with substantiated adverse findings in one State were actively 

certified in others. 

Twenty-eight State survey respondents reported that they did not 

remove records of inactive nurse aides from their registries as required, 

and over 99,000 nurse aides had active certifications in multiple States. 

Additionally, more than 1,500 nurse aides with substantiated findings 

had certifications in at least 1 other State, and were, therefore, 

potentially employable in that other State. More than 300 nurse aides 

had substantiated findings in more than 1 State. 

Some State-specific practices could make it more difficult to prevent 

certain individuals from working as nurse aides. 

State survey respondents reported using status classifications in their 

registries other than, and in addition to, those required in Federal 

regulation. In addition, some registries lacked complete information 

and many States relied on nurse aides to keep registry information 

up-to-date, contributing to inaccurate or out-of-date information 

existing on registries. 

RECOMMENDATIONS 

To assure that nurse aide registries effectively fulfill their intended 

purpose, we recommend that the Centers for Medicare & Medicaid 

Services (CMS): 

• Ensure States update records of nurse aides with substantiated 

adverse findings timely and remove registry records of nurse aides 

who have not performed nursing or nursing-related services for 

24 consecutive months, in accordance with Federal regulations. 

CMS could achieve this by: (1) issuing program memoranda that 

address updating nurse aide registry records, (2) conducting periodic 

reviews of State registries, or (3) implementing greater oversight. 

• Reduce the potential for nurse aides with substantiated findings to 

commit similar acts in another State. CMS could achieve this by 

seeking legislative authority to create a national nurse aide registry 

(a national registry also could be used to address identified data 

limitations, such as the lack of dates when substantiated findings 

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EXECUTIVE SUMMARY 

are placed on registries). CMS also could work with States to 

increase information sharing. 

• Work with States to ensure registry records contain current 

information on nurse aides. CMS could achieve this by requiring 

long-term care facilities to report current information of nurse aides 

they employ to the State registry upon hire and periodically 

thereafter. 

AGENCY COMMENTS 

We appreciate the level of detail that CMS provided in their comments 

to our recommendations. CMS generally concurred with our 

recommendations, and we note that CMS has taken action to address 

some of the findings raised in our report. 

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∆ T A B L E O F C O N T E N T S 

EXECUTIVE SUMMARY ......................................... i 

INTRODUCTION ................................................ 1 

FINDINGS ....................................................... 8 

Failure to update registries with substantiated adverse findings . 8 

Failure to remove records of inactive nurse aides from registries 

and individuals with substantiated adverse findings in one State 

were actively certified in others .............................. 10 

Practices make it more difficult to prevent certain individuals 

from working as nurse aides ................................. 13 

RECOMMENDATIONS ......................................... 16 

AGENCY COMMENTS ......................................... 18

APPENDIXES .................................................. 23 

A: Many States do not update registry records with 

substantiated adverse findings timely ..................... 23 

B: Nurse aides with substantiated adverse findings may have 

active certifications in other States ........................ 24 

C: Nurse aides with pending adverse findings may have 

active certifications in other States ........................ 25 

D: State suggestions and improvement efforts................. 26 

E: State compliance with specific registry components ......... 27 

F: Information available on the State nurse aide registry....... 28 

ACKNOWLEDGMENTS ......................................... 29 
C T I

OBJECTIVE

To determine State compliance with Federal regulations for

(1) updating the nurse aide registry records of nurse aides who have

substantiated findings of abuse, neglect, or misappropriation of

property, (2) removing the records of nurse aides who have not

performed nursing or nursing-related services for 24 consecutive

months, and (3) to review State nurse aide registry practices.

BACKGROUND

Federal Regulation

The Omnibus Budget Reconciliation Act of 1987 was designed to assure

delivery of quality care to long-term care facility residents. Federal

regulations (42 CFR 483. 156) require each State and the District 

Columbia (hereinafter referred to as a State) to maintain a nurse aide

registry of all individuals .who are certifed to work as nurse aides in

that State (all individuals who have completed nurse aide training and

that the State deems competent to function as nurse aides!) as well as

all individuals who have been prohibited from employment as nurse

aides in long-term care facilities because of substantiated findings of

abuse, neglect, or misappropriation ofproperty.2 Throughout the

report, we use the term "substantiated findings" to refer to State survey

and certification agencies' substantiated findings (against a nurse aide)

of abuse, neglect, or misappropriation of property.

Nurse aide registries must include at a minimum: (1) the full name of

the individual, (2) identifying information, (3) the date the individual

became eligible for placement in the registry, and (4) information

regarding substantiated findings (as appropriateP

1 Nurse aide refers to any individual who is not a licensed health professional, a registered

dietitian, or someone who volunteers to provide nursing or nursing-related services

without pay and who provides nursing or nursing-related services to residents in a facility

(42 CFR 483.75(e)). 2 The applicable regulations define abuse as "

... the wilful infliction of injury,

unreasonable confinement, intimidation, or punishment with resulting physical harm

pain or mental anguish." Neglect is defined as ". . . failure to provide goods and services

necessary to avoid physical harm, mental anguish, or mental ilness." Misappropriation of

resident property is defined as ". . . the deliberate misplacement, exploitation, or wrongful

temporary or permanent use of a resident's belongings or money without the resident'

consent. . . " (42 CFR 488.301).

42 CFR 483. 156(c)(I.

OEI- 07. 03- 00380 NURSE AIDE REGISTRIES: STATE COMPLIANCE AND PRACTICES
INTROD UCTION 

The nurse aide registry should include information only on those 

individuals who have “active” certifications and are thus employable 

and individuals whose records include substantiated findings. Federal 

regulations require States to remove registry records of individuals who 

have not performed nursing or nursing-related services for a period of 

24 consecutive months, thus becoming “inactive” and no longer 

employable.4 Individuals with records of substantiated findings must 

remain on the registry permanently, unless the findings were made in 

error, the individual was found not guilty in a court of law, or the State 

is notified of the individual’s death.5 The Balanced Budget Act of 1997 

(Public Law 105-33 § 4755) established the only exception, which allows 

nurse aides with substantiated findings of neglect to petition the State 

to have their name removed from the registry. Such an individual must 

wait at least 1 year from the date on which the substantiated finding 

was added to the State nurse aide registry, and the State must 

determine that the employment and personal history of the nurse aide 

did not reflect a pattern of abusive behavior or neglect, and that the 

neglect involved a singular occurrence. 

Purpose of State Nurse Aide Registries 

State nurse aide registries are intended to assure that long-term care 

facilities employ only certified nurse aides who do not have 

substantiated findings. Federal regulation requires long-term care 

facilities to not employ individuals who have a substantiated finding 

entered into the State nurse aide registry6 and to check the State 

registry before hiring nurse aides to verify competency.7 Assuring the 

integrity of States’ registries is a critical step in providing a safe living 

environment for more than one million, mostly elderly, residents in 

long-term care facilities nationwide.8 While the majority of nurse aides 

perform their duties without committing acts of abuse, neglect, or 

misappropriation of property, those who do create concerns. Examples 

of investigative case histories follow: 

• A nurse aide pushed a resident, causing the resident to fall to the 

floor. The nurse aide later retrieved a snow shovel from the kitchen, 

4 42 CFR § 483.156(c)(2). 

5 42 CFR § 483.156(c)(1)(iv)(D). 

6 42 CFR § 483.13(c)(1)(ii)(B). 

7 42 CFR § 483.75(e)(5). 

8 We will refer to nursing homes and skilled nursing facilities as long-term care facilities in 

this report. All CFR references refer to these facilities as long-term care facilities. 

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INTROD UCTION

and while the resident was still on the floor, struck the resident with 

the shovel and yelled that she was going to kill the resident (from 

the Virginia registry). 

• A nurse aide neglected a resident by leaving the resident in the 

facility transport van. The nurse aide left for the day at 

approximately 5:00 p.m. The resident was found alone in the van 

later that day at approximately 6:20 p.m. when he could not be 

located in the facility (from the North Carolina registry). 

• A nurse aide took a resident’s debit card without permission, got the 

personal identification number, and withdrew money from the 

resident’s bank account totaling approximately $1,100 over an 

unknown period of time (from the Texas registry). 

State survey and certification agencies receive and investigate 

allegations against nurse aides regarding abuse, neglect, or 

misappropriation of property. Federal regulations require placing 

information regarding a substantiated finding on the registry within 

10 working days of substantiating that finding.9 In 13 States, the State 

survey agency was responsible for both investigations and maintenance 

of the nurse aide registry. In 38 States, investigations were performed 

by 1 State agency and maintenance of the registry by another. 

Overview of State Nurse Aide Registries 

As of September 15, 2003, State nurse aide registries contained 

2.6 million nurse aide certifications in the United States.10 Out of these, 

39,061 records (33,768 unique individuals)11 were of nurse aides who 

were listed with substantiated findings and/or had their certifications 

revoked.12 There were an additional 14,243 records (13,435 unique 

individuals) of nurse aides who were listed as suspended or under 

investigation for abuse, neglect, or misappropriation of property. We 

note that Federal regulations do not require State nurse aide registries 

to maintain records of suspension or findings under investigation. 

9 42 CFR § 483.156(c)(1)(iv)(D). 

10 The results presented in this section are based on Office of Evaluation and Inspections 

analysis of nurse aide registry data during preparation for this report. 

11 There are more records than there are unique individuals because an individual nurse 

aide may be listed on more than one State registry. 

12 We use the term “revoked” to indicate nurse aides with denied, terminated, or revoked 

certifications or who have records with substantiated findings. 

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The size and scope of the registries varied greatly among States, 

ranging from 2,690 nurse aides in Alaska to 298,327 in Florida. The 

amount and types of information States stored on their registries also 

varied greatly. Some States included many details regarding topics 

such as identifying information, method and date of testing, certification 

and expiration dates, and the nature, investigation, and dates of any 

allegations or substantiated findings against the nurse aides; other 

States maintained registries that included only the information that 

Federal regulations specifically require. 

Other Studies Found Weaknesses with Registries 

Previous studies of nurse aide registries identified a number of 

weaknesses with registry practices in some States and indicated that 

State compliance with Federal nurse aide registry regulations was 

inconsistent. A 1997 Office of Inspector General (OIG) audit on the 

Maryland nurse aide registry reported that the registry did not always 

include information on all nurse aides with substantiated findings.13 A 

1998 OIG audit reported that criminal background checks were limited 

to State records, and individuals with criminal histories were not 

recorded on registries.14 

A 2002 Government Accountability Office (GAO) report also identified a 

number of potential problems with nurse aide registries.15 Based on a 

review of three States, GAO found that there were “frequent and long 

delays” in including information about substantiated findings on 

registry entries. The GAO also found that State registries only reflected 

a nurse aide’s history in that particular State, leaving open the 

possibility that long-term care facility residents could be exposed to 

nurse aides who had substantiated findings in other States, or whose 

registry records were not updated. Further, the report found that 

variations in the way that States applied the definition of abuse caused 

inconsistencies in nurse aide registry information across States. 

Finally, GAO found that one State’s electronic registry failed to update 

its Web site with substantiated findings. 

lan ’s O bu s a ram f r P ocessin e s d N g ect 13 State of Mary d m d m n Prog o r g Eld r Abu e an e l

Complai ts of Geriatri n c Nurse Aide Registry. Office of Inspector General, A-12-96-00016 

(11/97). 

gua di o r s de 14 Safe r ng L ng-Te m Care Re i nts. Office of Inspector General, A-12-97-00003 

(09/98). 

15 United States Government Accountability Office, Long-term C re Facilities: More Can a

Be D no e to Protect Resid n s f om Abu e e t r s , GAO-02-312 (Washington, DC: March 2002). 

 OEI-07-03-00380 NURSE AIDE REGISTRIES : S TATE C OMPLIANCE AND P RACTICES 4 
INTRODUCTION

METHODOLOGY 

This study was based on information from several different sources: 

(1) a review of Federal regulations regarding nurse aide registries; 

(2) a review of the existing literature and studies on nurse aide 

registries; (3) survey responses from the agencies responsible for the 

registries in all States; and (4) actual registry information and 

substantiated findings data from all States. 

State Survey 

We asked representatives from the State agencies that were responsible 

for maintenance of the registries and the investigative units in all 

States to complete an online survey regarding the practices, policies, 

and procedures they followed in maintaining their registries, their 

opinions on the effectiveness of their registry practices, and the 

challenges they faced in maintaining accurate information. We received 

responses from all such agencies. Where appropriate, we defined 

instances in which information came solely from survey data. 

Registry and Investigative Agency Data 

We requested and received data from all States comprising their entire 

nurse aide registry as of September 15, 2003. Per our request, the data 

included information on both employable nurse aides and those nurse 

aides with substantiated findings, as determined by the State survey 

and certification agency. For the 38 States that had a separate agency 

responsible for investigating allegations of abuse, neglect, or 

misappropriation of property, we also requested from the investigative 

agency a list of the nurse aides with substantiated findings between 

September 15, 2002, and September 15, 2003. Because a single agency 

handled both investigative and registry maintenance in the remaining 

13 States, we did not request a separate list of nurse aides with 

substantiated findings from those States because there was no data 

source independent from the registry itself to generate a list of nurse 

aides with substantiated findings in these States. These States were 

excluded from analyses used to determine if registries were updated 

timely with substantiated findings. 

Analysis 

For the 38 States with separate State registry maintenance and 

investigative agencies, we compared the list of substantiated findings 

provided by the investigative agency covering the period 

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September 15, 2002 through August 28, 200316 to the State registry 

data we received from the agency responsible for maintaining the 

registry to determine if all the nurse aides with substantiated findings 

on the investigative agency list also appeared on the registry having 

substantiated findings. Where nurse aides with substantiated findings 

were included on the investigative agency list but not on the nurse aide 

registry, we accessed the appropriate State registry 3 months later, in 

December 2003, by telephone or online to determine whether their 

records had been updated. 

We combined the nurse aide registry data from all States, including 

those nurse aides with substantiated findings, to create a simulated 

national nurse aide registry as of September 15, 2003. We then 

compared the data included in the simulated registry to determine how 

many nurse aides had active or revoked certifications in multiple 

States. We also analyzed the data provided by all 51 States to 

determine States’ compliance with Federal regulations regarding 

required information for nurse aides on the registry, including full 

name, identifying information, date of certification, and information 

regarding substantiated findings. 

Limitations of Updates to Registries and Multi-State Analysis 

Nurse aide registries did not consistently contain data regarding the 

date when findings were substantiated and/or when those findings were 

placed on the registries. Therefore, we could not determine exactly how 

many States failed to update registries with substantiated findings 

timely, nor could we determine how long it took States to update 

registries with substantiated findings in the 38 States where 1 agency 

was responsible for registry maintenance and another agency was 

responsible for investigations. We could not determine the number of 

records not updated timely that were at least 10 working days beyond 

the date the finding was substantiated. 

Our ability to definitively determine the number of nurse aides with 

certifications and/or substantiated findings in multiple States was 

compromised by the lack of a nationally unique identifier (i.e., Social 

Security number or national certification number) in nurse aide 

16 42 CFR § 483.156(c)(1)(iv)(D) requires that information be included within 10 working 

days of the finding; therefore, we reviewed substantiated findings up to 10 working days 

prior to September 15, 2003, or August 28, 2003. Federal law allows nurse aides with 

findings of neglect to petition to have their names cleared after 1 year; thus, we limited 

our scope to a period of 1 year. 

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INTRODUCTION

registries across all States. Therefore, we included only exact matches 

based on nationally unique identifiers that did exist (e.g., we matched 

Social Security numbers for States that provided us this information) 

when identifying nurse aides with certifications and/or substantiated 

findings in multiple States. Because of these limitations, our estimate 

of the magnitude of nurse aide movement between States was 

conservative. 

Standards 

This inspection was conducted in accordance with the Quality 

Standar s for Inspecti d ons issued by the President’s Council on Integrity 

and Efficiency. 

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Federal regulations require

that State survey and

certification agencies list

nurse aides with substantiated findings on the State nurse aide registry

within 10 working days of the substantiation ofthe finding.1 Based 

the previously described data limitations , we believe our estimates of

failure to comply, both in terms of number of States and number of

records not updated timely, are conservative.

Some States failed to update registries with

substantiated adverse findings

Twenty-four States reviewed did not meet Federal regulations for updating

registry records of nurse aides with substantiated adverse findings timely;

one in four nurse aide records were not updated with recent substantiated

adverse findings.

Based on our comparison of investigative agency and registry data, at

least 24 of the 38 States with separate registry maintenance and

investigative agencies 18 had substantiated findings that were not

updated in their respective registries as of September 15, 2003

10 working days after the end of our review period (see Appendix A).

In addition to the 24 noncompliant States, survey respondents from

4 other States acknowledged that it typically took them more than the

required 10 working days to update their registries with information

about substantiated findings. However, survey respondents from 19 of

the 24 States that we found to be out of compliance based on registry

data indicated that they believed they typically met the 10 working day

requirement contained in the regulation.

Thirty-eight States with separate registry maintenance and

investigative agencies had substantiated findings against 1 978 nurse

aides from September 15, 2002, through August 28, 2003. 19 Of these

23 percent (450/1 978) ofthe nurse aides' records were not updated with

substantiated findings on the appropriate State s registry as of

September 15, 2003, 10 working days after the end of our review period.

Although the State survey and certification agencies had substantiated

findings for these 450 nurse aides, the nurse aides were potentially

employable in any long-term care facility in that State because their

17 42 CFR ~ 483. 156(b)(2) and 42 CFR ~ 483. 156(c)(I(iv)(D).

18 Thirty-eight States had two separate agencies responsible for investigating allegations

and maintaining the registry. Thirteen States had one agency responsible for both

investigating allegations and maintaining the registry; therefore, it was not possible to

obtain an independent list of the nurse aides who had substantiated findings.

19 August 28, 2003, is 10 working days prior to September 15, 2003.

OEI- 07- 03- 00380 NURSE AIDE REGISTRIES: STATE COMPLIANCE AND PRACTICES
F INDING S 

registry records did not include information on their substantiated 

findings. 

Because most States did not record the dates they added substantiated 

findings to their registries, we were unable to determine when the 

remaining 1,528 (1,978 less 450) substantiated findings were updated 

on the appropriate registries. It is, therefore, possible that the number 

of noncompliant States and the number of nurse aide records not 

updated within the required 10 working days could be higher. For 

example, had a record with a substantiated finding been updated 

30 days after substantiation, but before September 15, 2003, we would 

not have identified it based on the methods available to us to assess 

compliance. 

Almost one in eight nurse aide records with substantiated adverse findings 

were not updated 3 months later. 

In December 2003, we accessed the registries of those 24 States in 

which we found 450 nurse aides with substantiated findings whose 

records were not updated as of September 15, 2003. Upon completion of 

the second review, 236 records of nurse aides still were not updated 

with substantiated findings.20 Thus, 3 months later, and after States 

were aware of our study, 12 percent (236/1,978) of the records of nurse 

aides with substantiated findings, representing 19 States, still were not 

updated. 

Two examples of the behavior that led to substantiated findings for 

nurse aides whose records were not updated on the registry, taken from 

information the investigative agencies provided, follow: 

• A nurse aide poured milk on a resident’s head, grabbed his arms 

and pushed him back into the wheelchair, and hit him on the head, 

causing multiple skin tears and bruises (from the Texas 

investigative agency). 

• A nurse aide struck a resident in the face, fracturing his nose, and 

breaking his glasses (from the Alaska investigative agency). 

20 Florida State officials indicated that responsibility for the nurse aide registry transferred 

among different agencies within the State. Few record updates of nurse aides with 

substantiated findings occurred during these transitions. None of the 109 nurse aides 

with substantiated findings in Florida during our review period were identified as such 

on the nurse aide registry at any time during our review. 

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FINDINGS FINDINGS 

The well-being of long-term care facility residents was placed at risk 

because these nurse aides continued to appear employable due to 

registry records not updated to reflect their substantiated findings. 

Over half of State respondents reported failure 

to remove records of inactive nurse aides from 

registries; some individuals with substantiated 

adverse findings in one State were 

actively certified in others 

As of September 15, 2003, 

2.6 million nurse aides were listed 

with active certifications on nurse 

aide registries nationwide, with 

99,006 having active certifications 

in more than 1 State (see Table 1). 

Many States failed to remove records of inactive nurse aides from their 

registries. 

Federal regulations do not prohibit nurse aides from holding 

certifications in different States simultaneously; however, Federal 

regulations require States to remove from the registries the records of 

nurse aides who have not performed nursing or nursing-related services 

for a period of 24 consecutive months, as long as the nurse aides’ records 

do not contain substantiated findings.21 

Survey respondents from 28 of 51 States 

reported that they did not remove the 

records of nurse aides who failed to 

maintain their certification. Five of these 

twenty-eight States reported that the 

status of records was changed when nurse 

aides failed to maintain their certification; 

however, the remaining 23 States did not 

report making a distinction between the 

records of active and inactive nurse aides 

on the registry. Oftentimes, the nurse aide 

registry data available to us did not allow 

Table 1: Number of Nurse 

Aides with Certifications in 

Multiple States 

Number of 

States 

Number of 

Nurse Aides 

2 93,697 

3 4,919 

4 342 

5 35 

6 10 

7 1 

9 1 

10 1 

Total 99,006 

us to determine if nurse aide records 

Source: OIG analysis of all collected should be removed from the registry. nurse aide registry records 

States failing to remove the records of inactive nurse aides could lead to 

nurse aides being employed in long-term care facilities even though they 

have not maintained their certification or, more significantly, returning 

21 42 CFR § 483.156(c)(2). 

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FINDINGS FINDINGS 

to a State where they have an active certification despite having a 

substantiated finding in another State. 

Some States acknowledged failing to remove the records of nurse aides 

who had not maintained their certifications and our analysis showed 

that some of the nurse aides with multiple certifications held them in 

nonneighboring States. Thus, it was possible that some of the 

99,006 nurse aides with more than 1 active certification should have 

had their records in the other State(s) removed to reflect that the 

certification was no longer active. 

More than 2,000 nurse aides with substantiated or pending adverse findings 

in 1 State had active certifications in other States. 

A total of 1,552 nurse aides with either substantiated findings and/or 

revoked certifications, and another 450 nurse aides with pending 

findings in a State were also actively certified in 1 or more other States 

(see Table 2). A detailed State breakdown for substantiated findings 

can be found in Appendix B and pending findings in Appendix C. 

Nurse aides with 

Table 2: Nurse Aides with Substantiated or pending or Pending Findings Actively Certified in Other substantiated States

findings not only held 

active certifications Number of Nurse Number of 

Actively Aides with Nurse Aides in neighboring 

Certified in Substantiated with Pending States, but also held Findings Findings active certifications 

across the Nation. 1 State 1,412 418 

2 States 122 29 For example, 3 States 14 3 33 nurse aides with 4 States 3 0

substantiated 5 States 1 0 

findings from Total 1,552 450 

Virginia had active Source: OIG analysis of all collected nurse aide registry 

certifications in records 

Florida, and 19 nurse aides with substantiated findings in California 

had active certifications in Illinois. 

The data provided did not allow us to conclude where the nurse aides 

resided at the time of our study. In addition, the data did not allow us 

to determine the date the findings were substantiated in one State or 

the dates the certifications were granted in another State. Thus, the 

active certification in one State could have been granted before or after 

the nurse aide had a substantiated finding in a different State. 

O E I - 0 7 - 0 3 - 0 0 3 8 0 NURSE AIDE REGISTRIES : S TATE C OMPLIANCE AND P RACTICES 11 
FINDING S 

More than 300 nurse aides had substantiated adverse findings in multiple 

States. 

Based on the data we received, we were able to conclusively identify 

314 nurse aides who had records with matching unique identifiers and 

substantiated findings in multiple States (i.e., the same individual had 

different substantiated findings in different States). Our analysis 

indicated that there could be as many as 4,569 nurse aides with unique 

substantiated findings in multiple States. However, due to how States 

maintained information in their registries, we could not definitely 

determine whether substantiated findings of some nurse aides were 

unique, independent events or were instead substantiated findings 

included on that State’s registry, but had occurred in another State. 

Some individuals who had substantiated adverse findings as nonnurse 

aides in one State were actively certified as nurse aides in others. 

The data that Arkansas provided allowed us to identify 3,391 nonnurse 

aides (e.g., staff who were not nurse aides, such as janitors) with 

histories of abuse. Of these, 1 percent (36/3,391) also had records listing 

them as active nurse aides in at least 1 other State. Since we were only 

able to assess the number of nonnurse aides with substantiated findings 

from one State, it was possible that similar situations existed in other 

States. 

Despite States’ efforts, nurse aides with substantiated adverse findings had 

active certifications. 

According to survey data, 33 States responded that they included 

substantiated findings from other States on their registries and that an 

out-of-State finding disqualified a nurse aide from certification and 

employment in their respective State.22 Yet, as of September 15, 2003, 

32 of these 33 States had an active certification for at least 1 nurse aide 

who was prohibited from working in another State. As previously 

stated, data available in State registries did not always allow us to 

determine when a substantiated finding was placed on a registry; 

therefore, we could not determine if the substantiated finding occurred 

before or after a certification was issued in these 32 States. Possible 

explanations as to how nurse aides with substantiated findings could 

become certified in a new State include: (1) while a certification in one 

State remains active, the nurse aide moves to a new State, becomes 

22 Twelve additional States indicated that a substantiated finding in another State would 

have to be reviewed before they might disqualify the nurse aide from working in their 

State. 

O E I - 0 7 - 0 3 - 0 0 3 8 0 NURSE AIDE REGISTRIES : S TATE C OMPLIANCE AND P RACTICES 12 
FINDINGS FINDINGS 

certified, and subsequently abuses, neglects, or misappropriates a 

resident’s property; (2) the State where the offense occurred does not 

enter the substantiated finding on the registry timely, thus allowing the 

nurse aide to appear employable in another State; or (3) the new State 

does not become aware of the substantiated finding because of 

inadequate information sharing. These problems are exacerbated when 

States do not remove records of nurse aides from registries as required. 

States have implemented Some State-specific practices could make it varying practices in the more difficult to prevent certain individuals maintenance of their 

from working as nurse aides registries. For example, some 

States used status classifications other than those required in Federal 

regulation and States differed in their efforts to update registry 

information. Some of these practices, while beneficial to the individual 

States, may increase difficulties as other States work to prevent certain 

individuals (e.g., those with substantiated findings) from working as 

nurse aides. This problem is compounded when the information 

contained on registries is inaccurate or incomplete. 

Although we did not specifically ask State survey respondents about a 

national nurse aide registry, the most commonly suggested 

improvement was the creation of a national registry. Twenty State 

survey respondents expressed the opinion that a national registry would 

be helpful, both for reciprocity purposes and in preventing nurse aides 

with substantiated findings from working in other States.23 See 

Appendix D for examples of efforts some States have undertaken to 

improve their registry processes and State survey respondents’ 

suggestions for improvement. 

Eighteen States used status classifications in addition to those Federal 

regulations require. 

Substantiated findings leading to prohibition of employment as a nurse 

aide were not the only punitive sanctions that States established and 

maintained in their State registries. Eighteen States had various 

OEI-07-03-00380 

23 Reciprocity is a process by which a certified nurse aide from another State may qualify 

for certification in a new State by virtue of his or her status in the previous State. An 

individual is only eligible for reciprocity if he or she has been entered on a nurse aide 

registry in another State in accordance with the training and competency evaluation 

requirements of the Omnibus Budget Reconciliation Act of 1987, as amended, and if the 

individual is currently listed on that State’s nurse aide registry as active and without 

substantiated findings. 

NURSE AIDE REGISTRIES : S TATE C OMPLIANCE AND P RACTICES 13 
FINDING S 

status classifications to distinguish levels of misconduct. For example, 

we encountered status classifications such as “Suspended,” “Revoked,” 

“Dismissed,” “Lapsed,” and “Lapsed-Conditional” in one State’s registry 

(in addition to the federally required indications of nurse aides with 

substantiated findings). Another State had 40 status classifications to 

classify the various dispositions of individuals listed on their registry. 

Nationwide, we found that 14,243 nurse aide records were listed as 

“Suspended,” “Surrendered,” “Pending,” or some similar status 

classification. From the information States provided, we were unable to 

determine if the acts indicated within these other status classifications 

fit the Federal definition of abuse, neglect, or misappropriation of 

property. This created a potential challenge for another State 

attempting to use this information in determining whether to certify an 

individual as a nurse aide. 

While Federal regulations do not require States to do so, 10 of 51 States 

reported pending cases of abuse, neglect, or misappropriation of 

property on the registry before the case had actually been 

substantiated, thus alerting employers of potential problems. One State 

noted this as a special concern because it could result in nurse aides 

who did not have substantiated findings being prohibited from 

employment. Four other States noted pending cases on a section of the 

registry that was not available to the public. 

Most States relied on nurse aides to keep registry information up-to-date. 

Survey respondents from 48 States reported that they relied mainly on 

the nurse aides themselves to report changes in personal information 

directly to the registry. However, this approach did not work 

effectively. Eighteen State survey respondents indicated that they 

experienced difficulties in keeping accurate and up-to-date personal 

information, such as names, addresses, and renewals of certification, in 

their registries. Eleven State survey respondents expressed that nurse 

aides frequently changed employers and residences, making it difficult 

to assure that the nurse aides’ most recent information was available. 

 O E I - 0 7 - 0 3 - 0 0 3 8 0 NURSE AIDE REGISTRIES : S TATE C OMPLIANCE AND P RACTICES 14 
FINDING S 

Several State registries lacked complete information. 

We reviewed individual State nurse aide registry records for full name, 

certification date, and other identifying information as provided in 

42 CFR § 483.156(c)(1). According to registry data, 45 of 51 States had 

at least 95 percent of all records with the 3 basic fields completed, while 

6 States had less than 90 percent of records with at least 1 required 

field complete (see Table 3 for general and Appendix E for specific 

information).24 A listing of data elements contained in State registries 

appears in Appendix F.25 Given that Federal regulations do not require 

States to maintain a nationally unique identifier for nurse aide records, 

information that could be used in lieu of such an identifier becomes 

more important. 

Table 3: State Level of Compliance with Federal Requirements 

Requirement Level of Compliance Number of States 

Full Name 

100% 24 

90-99+% 26 

below 90% 1 

Identifying 

Information* 

100% 40 

99-99+% 11 

Date Certified 

100% 19 

90-99+% 28 

70-89+% 4 

below 70% 1 *

Social Security number, certification or license number, date of birth, or other State 

specific identifier 

Source: OIG analysis of all collected nurse aide registry records 

24 We included records of nurse aides deemed active on the registry, as well as those with 

revoked or terminated certifications and indications of abuse, neglect, or 

misappropriation. The table reflects key regulations as listed in 42 CFR § 483.156(c)(1). 

25 Information in Table 3 is based on review of actual registry data, whereas, Appendix F is 

based on States’ responses to our survey questions. Discrepancies between the two tables 

result from differences between what States reported to us and what we observed in their 

data. 

OEI-07-03-00380 NURSE AIDE REGISTRIES : S TATE C OMPLIANCE AND P RACTICES 15 
R E C 0 D A T I N S

OEI- 07- 03- 00380

RECOMMENDATIONS

Nurse aide registries are intended to assure that only certifed nurse

aides without substantiated findings on their records are employed in

long-term care facilities. Noncompliance with registry processes, such

as the failure to list substantiated findings of nurse aides on registry

records timely, and the failure to remove nurse aides who have not

maintained an active certification, exposes long-term care facility

residents to greater risk of harm.

To assure that nurse aide registries effectively fulfll their intended

purpose, we recommend that CMS:

Ensure States update records of nurse aides with substantiated

adverse findings timely and remove registry records of nurse aides

who have not performed nursing or nursing-related services for

24 consecutive months, in accordance with Federal regulations.

CMS could achieve this by: (1) issuing program memoranda that

address updating nurse aide registry records, (2) conducting periodic

reviews of State registries, or (3) implementing greater oversight.

Reduce the potential for nurse aides with substantiated findings to

commit similar acts in another State. CMS could achieve this by

seeking legislative authority to create a national nurse aide registry

(a national registry also could be used to address identified data

limitations, such as the lack of dates when substantiated findings

are placed on registries). CMS also could work with States to

increase information sharing.

Work with States to ensure registry records contain current

information on nurse aides. CMS could achieve this by requiring

long-term care facilities to report current information of nurse aides

they employ to the State registry upon hire and periodically

thereafter.

AGENCY COMMENTS

We appreciate the level of detail that CMS provided in its comments to

our recommendations. CMS generally concurred with our

recommendations, and we note that CMS has taken action to address

some of the findings raised in our report.

NURSE AIDE REGISTRIES: STATE COMPLIANCE AND PRACTICES
RECOMMENDATIONS 

CMS has committed to issuing additional communications to States 

affirming that all findings of abuse, neglect, and misappropriation of 

resident property must be included in the nurse aide registry within 

10 working days of the finding, and the names of nurse aides who have 

performed no nursing or nursing-related services for 24 consecutive 

months must be promptly removed from the nurse aide registry. In 

addition, CMS will follow up with some of the States that seem to have 

the most serious problems in maintaining an effectively functioning 

nurse aide registry and offer support for a limited number of States that 

wish to undertake quality improvement projects to improve the effective 

operation of their nurse aide registry. Finally, CMS will consider a 

variety of methods to work with States to ensure registry records 

contain current information on nurse aides. 

OEI-07-03-00380 NURSE AIDE REGISTRIES : S TATE C OMPLIANCE AND P RACTICES 17 
∆ AGENCY COMMENTS 

OEI-07-03-00380 NURSE AIDE REGISTRIES : S TATE C OMPLIANCE AND P RACTICES 18 
AGENCY COMMENTS

OEI-07-03-00380 NURSE AIDE REGISTRIES : S TATE C OMPLIANCE AND P RACTICES 19 
AGENCY COMMENTS

OEI-07-03-00380 NURSE AIDE REGISTRIES : S TATE C OMPLIANCE AND P RACTICES 20 
AGENCY COMMENTS

OEI-07-03-00380 NURSE AIDE REGISTRIES : S TATE C OMPLIANCE AND P RACTICES 21 
AGENCY COMMENTS

OEI-07-03-00380 NURSE AIDE REGISTRIES : S TATE C OMPLIANCE AND P RACTICES 22 
∆ APPENDIX ~ A 


Many States do not update registry records with substantiated adverse findings 

timely 

In 38 States, 2 separate agencies were responsible for maintaining the 

registry and investigating allegations of abuse, neglect, or 

misappropriation of property. These States are listed below along with 

the number of nurse aides with substantiated findings based on 

information provided to us by the State investigative agency. The 

number of nurse aides with substantiated findings identified in the 

registries in September 2003 and December 2003 is listed along with 

the remaining number of nurse aides yet to be updated on their registry 

record at the conclusion of our review. “Updated by 12/03” includes both 

nurse aides updated as of September 15, 2003, and those who were 

updated in the 3 months leading to December 2003. 

State 

Nurse Aides 

with 

Substantiated 

Adverse 

Findings 

Updated 

by 9/15/03 

Updated 

by 12/03 

Yet to be 

Updated 

by 12/03 

AK 3 1 1 2 

AL 98 98 98 0 

AZ 93 89 92 1 

CA 107 93 102 5 

CO 36 32 35 1 

CT 36 1 36 0 

DC 1 1 1 0 

DE 15 15 15 0 

FL 109 0 0 109 

HI 3 3 3 0 

ID 15 14 15 0 

IL 290 227 289 1 

IN 18 15 15 3 

KS 7 7 7 0 

KY 42 40 40 2 

LA 14 14 14 0 

MD 19 17 19 0 

ME 57 41 41 16 

MI 33 28 32 1 

MN 66 66 66 0 

State 

Nurse Aides 

with 

Substantiated 

Adverse 

Findings 

Updated 

by 9/15/03 

Updated 

by 12/03 

Yet to be 

Updated 

by 12/03 

MT 49 0 38 11 

NC 83 83 83 0 

NV 9 9 9 0 

NY 102 83 86 16 

OH 91 83 89 2 

OK 101 60 84 17 

OR 4 1 4 0 

PA 29 27 28 1 

SC 18 18 18 0 

SD 6 6 6 0 

TN 26 25 26 0 

TX 97 54 59 38 

UT 10 9 10 0 

VA 45 45 45 0 

VT 15 0 7 8 

WA 78 78 78 0 

WI 148 140 146 2 

WY 5 5 5 0 

Total 1,978 1,528 1,742 236 

Source: OIG analysis of all collected nurse aide registry records 

OEI-07-03-00380 NURSE AIDE REGISTRIES : S TATE C OMPLIANCE AND P RACTICES 23 
∆ APPENDIX ~ B 


Nurse aides with substantiated adverse findings may have active certifications in 

other States 

The table below summarizes the number of nurse aides with 

substantiated findings in one State and active certifications in another 

at the time of our review.1 In the table below, “Certified Nurse Aides 

with Substantiated Adverse Findings in Other States” refers to the 

number of active nurse aides in that State with substantiated findings 

in a different State.2 For example, Alabama (AL) had 42 active nurse 

aides who each had substantiated findings in at least 1 of 18 different 

States. 

State 

Certified Nurse Aides 

with Substantiated 

Adverse Findings in 

Other States 

Number of 

Other States 

AK 1 1 

AL 42 18 

AR 35 10 

AZ 9 7 

CA 21 10 

CO 21 10 

CT 40 17 

DC 19 4 

DE 4 4 

FL 222 34 

GA 45 19 

HI 3 3 

IA 12 6 

ID 7 6 

IL 280 29 

IN 18 12 

KS 27 10 

KY 110 19 

LA 135 20 

MA 6 6 

MD 18 6 

ME 4 3 

MI 6 5 

MN 21 10 

MO 31 9 

State 

Certified Nurse Aides 

with Substantiated 

Adverse Findings in 

Other States 

Number of 

Other States 

MS 11 9 

MT 8 5 

NC 42 16 

ND 10 6 

NE 13 6 

NJ 15 5 

NM 24 14 

NV 5 3 

NY 31 17 

OH 132 30 

OK 52 16 

OR 6 4 

PA 30 14 

RI 4 2 

SC 12 7 

SD 28 12 

TN 15 10 

TX 62 17 

UT 4 3 

VA 26 16 

WA 34 14 

WI 1 1 

WV 10 4 

WY 3 2 

Source: OIG analysis of collected nurse aide registry records 

1 New Hampshire did not use a nationally unique identifier; therefore, we were unable to 

evaluate interstate movement for this State. Vermont only supplied a nationwide unique 

identifier for nurse aides with substantiated findings; therefore, we were unable to 

determine whether nurse aides with substantiated findings from other States had active 

certifications in Vermont. 

2 There are 1,715 records for the 1,552 nurse aides because some nurse aides with 

substantiated findings may be listed as active in more than 1 State. Only States with 

values are listed. 

OEI-07-03-00380 NURSE AIDE REGISTRIES : S TATE C OMPLIANCE AND P RACTICES 24 
∆ APPENDIX ~ C 


Nurse aides with pending adverse findings may have active certifications in other 

States 

The table below summarizes the number of nurse aides with pending 

findings in one State and active certifications in another at the time of 

our review.3 In the table below, “Certified Nurse Aides with Pending 

Adverse Findings in Other States” refers to the number of active nurse 

aides in that State with pending findings in a different State.4 For 

example, Alabama (AL) had 12 active nurse aides who each had pending 

findings in at least 1 of 4 different States. 

State 

Certified Nurse 

Aides with Pending 

Adverse Findings in 

Other States 

Number of Other 

States 

AK 1 1 

AL 12 4 

AR 5 3 

AZ 9 3 

CA 3 3 

CO 4 2 

CT 10 2 

DC 3 1 

FL 116 9 

GA 14 7 

HI 1 1 

IA 8 4 

ID 3 1 

IL 21 6 

IN 1 1 

KS 3 3 

KY 11 5 

LA 13 3 

MA 15 4 

MD 3 2 

ME 2 2 

MI 2 2 

MN 1 1 

State 

Certified Nurse 

Aides with Pending 

Adverse Findings in 

Other States 

Number of Other 

States 

MO 8 4 

MT 3 1 

NC 16 5 

ND 4 3 

NE 5 2 

NJ 2 1 

NM 8 3 

NV 2 1 

NY 37 4 

OH 28 8 

OK 17 4 

OR 2 1 

PA 6 3 

RI 5 3 

SC 10 5 

SD 8 3 

TN 5 3 

TX 13 2 

UT 2 1 

VA 11 6 

WA 28 6 

WV 3 1 

WY 1 1 

Source: OIG analysis of collected nurse aide registry records 

OEI-07-03-00380

3 New Hampshire did not use a nationally unique identifier; therefore, we were unable to 

evaluate interstate movement for this State. Vermont only supplied a nationwide unique 

identifier for nurse aides with substantiated findings; therefore, we were unable to 

determine whether nurse aides with pending findings from other States had active 

certifications in Vermont. 

4 There are 485 records for the 450 nurse aides because some nurse aides with pending 

findings are listed as active in more than 1 State. Only States with values are listed. 

N URSE AIDE REGISTRIES : S TATE C OMPLIANCE AND P RACTICES 25 
∆ APPENDIX ~ D 

State suggestions and improvement efforts 

State Efforts 

• Some States shared with other States data on nurse aides with 

substantiated findings. For example, 1 State received lists of nurse 

aides with substantiated findings from 13 States, and sent out their 

own list to all States every 3 months. However, one State received 

information from other States, but had no way to record it on their 

present database. 

• Five States required long-term care facilities to periodically check 

their registry to ensure that employed nurse aides renewed their 

certifications. 

• Twenty-one of fifty-one States conducted criminal background 

checks before certification and may deny certification based on the 

results. However, only 10 of these States reported the findings of 

those criminal background checks on their registries. 

• Of the States that conducted criminal background checks, 10 States 

reported conducting national checks. One State reviewed every 

address where the nurse aide had ever lived, while another reviewed 

for convicted criminal acts within the past 20 years. 

State Survey Respondents’ Suggestions for Improvement 

• Twenty States proposed creation of a national nurse aide registry. 

• Eight States proposed increasing automation of the registry 

processes. 

• Three States suggested implementing better methods for keeping 

nurse aides’ personal information up-to-date. 

• Five States included results of criminal background checks on 

registry records. 

OEI-07-03-00380 NURSE AIDE REGISTRIES : S TATE C OMPLIANCE AND P RACTICES 26 
∆ APPENDIX ~ E 

State compliance with specific registry components 

The table below summarizes, by State, the percentage of records with 

full name, identifying information, and certification date fields complete 

as of September 15, 2003. All numbers were based on the total 

population of active nurse aides and nurse aides with substantiated 

adverse findings. This population is labeled “Records.” We excluded 

nurse aides with inactive records and nurse aides whose records were 

clearly marked on the registry as having substantiated findings from 

another State. 

State Records Full Name Identifying 

Information 

Certification 

Date 

AK 2,690 99.963% 100% 98.959% 

AL 71,120 99.999% 99.999% 99.999% 

AR 22,422 99.996% 100% 99.938% 

AZ 22,311 99.996% 99.996% 97.176% 

CA 131,022 99.997% 100% 100% 

CO 25,462 99.988% 100% 100% 

CT 61,762 99.953% 99.955% 99.955% 

DC 4,965 100% 100% 100% 

DE 5,624 100% 100% 100% 

FL 298,327 99.997% 100% 100% 

GA 57,876 99.998% 100% 100% 

HI 8,367 100% 100% 99.988% 

IA 38,080 100% 100% 71.657% 

ID 11,639 99.991% 100% 100% 

IL 283,717 99.994% 100% 100% 

IN 43,612 99.989% 99.998% 99.819% 

KS 38,443 100% 100% 100% 

KY 93,656 99.996% 100% 36.208% 

LA 121,816 99.984% 100% 100% 

MA 48,844 100% 100% 99.679% 

MD 18,769 99.995% 100% 99.995% 

ME 18,122 99.906% 100% 96.441% 

MI 41,098 100% 100% 100% 

MN 50,609 33.739% 100% 99.945% 

MO 62,288 99.989% 99.998% 99.255% 

MS 16,572 100% 100% 98.678% 

State Records Full Name Identifying 

Information 

Certification 

Date 

MT 9,632 100% 99.990% 99.886% 

NC 104,319 100% 100% 99.995% 

ND 15,469 100% 100% 76.023% 

NE 25,141 99.992% 99.992% 99.992% 

NH 12,228 100% 100% 99.207% 

NJ 28,802 99.993% 100% 100% 

NM 23,629 99.979% 100% 99.945% 

NV 5,731 100% 99.215% 99.215% 

NY 102,646 100% 100% 100% 

OH 195,903 96.200% 99.999% 99.836% 

OK 44,753 100% 99.991% 99.806% 

OR 17,918 99.994% 100% 100% 

PA 85,997 100% 100% 100% 

RI 10,563 100% 100% 99.328% 

SC 23,849 100% 100% 100% 

SD 19,501 100% 100% 99.995% 

TN 32,704 99.997% 100% 99.966% 

TX 107,718 100% 100% 100% 

UT 14,360 100% 100% 100% 

VA 46,154 99.417% 99.417% 89.095% 

VT 4,674 100% 100% 99.080% 

WA 49,055 99.994% 100% 80.349% 

WI 58,237 99.998% 100% 99.840% 

WV 14,235 100% 100% 99.993% 

WY 4,996 100% 100% 100% 

Source: OIG analysis of all collected nurse aide registry records 

OEI-07-03-00380 NURSE AIDE REGISTRIES : S TATE C OMPLIANCE AND P RACTICES 27 
∆ APPENDIX ~ F 

Information available on the State nurse aide registry 

This table summarizes States’ survey responses regarding the types of 

information contained in their registry. 

Description Number of States 

(including DC) 

Full Name 51 

Substantiated Findings 50 

Social Security Number 48 

Date of Birth 47 

Date of Certification 39 

Record of Changes to Registry 37 

Employment Verification 14 

Criminal Background Check 10 

Source: Data reported by State respondents 

OEI-07-03-00380 NURSE AIDE REGISTRIES : S TATE C OMPLIANCE AND P RACTICES 28 
∆ ACKNOWLEDGMENTS 


This report was prepared under the direction of Brian T. Pattison, 

Regional Inspector General for Evaluation and Inspections in the 

Kansas City regional office, and Gina C. Maree, Assistant Regional 

Inspector General. Other principal Office of Evaluation and Inspections 

staff who contributed include: 

Brian T. Whitley, P oj t Lead r ec er 

Dennis Tharp, Program Analyst 

Michala Walker, Program Analyst 

Tricia Fields, Program Analyst 

Sandy Khoury, Program Specialist 

Tricia Davis, Director, Medicare & Medicaid Branch

Technical Assistance 

Barbara Tedesco, Mathematical Statistician 

OEI-07-03-00380 NURSE AIDE REGISTRIES : S TATE C OMPLIANCE AND P RACTICES 29