My facility just completed our annual survey and is in denial of payment until a Directed In-Service training is completed. What is a Directed In-Service training and how do we ensure compliance?



Directed In-service training is one of the enforcement actions that may be imposed as a remedy in accordance with 42 CFR §488.406. The purpose of remedies is to ensure a prompt return to compliance with program requirements following a deficiency being cited.  The following points related to Directed Inservice Training are outlined in Chapter 7 of the SOM:

Directed In-service training

      • Is considered as a remedy in cases where you have deficiencies where there are knowledge gaps in standards of practice, staff competencies or the minimum requirements of participation and where education is likely to correct the noncompliance.
      • CMS recommends that facilities use programs developed by well-established centers of geriatric health services such as schools of medicine or nursing, centers for the aging, and area health education centers which have established programs in geriatrics and geriatric psychiatry for directed in-service training.  Some states have lists developed with recommended programs.
      • The facility bears the expense of the directed in-service training.

Directed In-service training may by required to be completed by an independent post-acute care consultant, and specific training requirements must be covered related to the identified deficiency.  Training must be completed for all relevant staff with written documentation of the inservice (e.g. sign in sheets, training content, pre/posttest and, as necessary, competency assessment for participants.) A report from the consultant completing the training may be required, which validates the trainer’s subject matter expertise and includes an attestation statement confirming training completion.  Contact Proactive for assistance with Directed In-service training.


Amie Martin, OTR/L, CHC, RAC-CT, MJ

Learn more about the rest of the Proactive team.