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CNA will document the Work Group's findings and recommended options to CMS. CNA will use this information to produce two working papers and a report.

Working Papers:

  • Working Paper 1 – Definitions of a "direct access employee."
  • Working Paper 2 – State convictions that disqualify individuals from direct access employment with LTC facilities/providers, which conviction types are considered for mitigation or rehabilitation, and the time period for which each conviction disqualifies individuals from employment.


  • Report – Findings and options from the Work Group to CMS.

Work Group Meeting Materials