Issue Paper

Use of "Single Task" Employees in Nursing Homes


The language below should be added to the Medicare and Medicaid statutes to give nursing facilities the flexibility to use non-nursing, “single task” employees to assist residents with eating under certain circumstances.

Create ss.1819(b)(5)(H) and 1919(b)(5)(H) of the Social Security Act to read:

(H) Non-Nursing Personnel Performing Limited Duties.

  1. Nursing facilities may permit personnel other than nurse aides to provide assistance with eating without completing the nurse aide training and competency evaluation program or the competency evaluation program if they have acquired necessary knowledge and skills through an inservice training program that includes dining skills and assistance with eating and that has been reviewed and approved by the regulatory authority, and they have been found competent to perform their duties.

  2. The determination of ability to provide assistance with eating will be made by an interdisciplinary team, to include at a minimum, licensed nursing, dietary, speech therapy and occupational therapy staff responsible for the care of the resident. The determination will be based on the needs and potential risks to the resident as observed and documented in the comprehensive resident assessment and care plan.

  3. The facility will document that the interdisciplinary team has assessed the resident to determine that his or her health status does not require the assistance with eating to be performed by nursing personnel.

  4. Non-nursing personnel providing assistance with eating may augment, but not replace, existing staff and cannot be counted toward meeting or complying with requirements for nursing care staff and functions.


A “single task” employee is an employee who neither is a licensed professional nurse nor a certified nursing assistant (CNA) listed on the State’s nurse aide registry who is permitted to perform a single direct care task. Examples include an activities assistant assigned to help feed a resident or a dietary aide who pushes a resident in her wheelchair to dinner. “Single task” employees are non-nursing personnel used to provide support to nursing staff primarily in the areas of feeding, transportation and mobility, and activities. Because they are not CNAs, “single task” employees have not completed the nurse aide training and competency evaluation program.

Wisconsin has reviewed and approved requests by nursing facilities to use “single task” employees since 1993. Last month, however, officials from the federal Health Care Financing Administration (HCFA) challenged Wisconsin’s “single task” employee policy during a visit to the Bureau of Quality Assurance (BQA) in Wisconsin’s Department of Health and Family Services (DHFS). According to those HCFA officials, federal law does not allow facilities to use single task employees to assist residents with feeding (no concerns were raised with transporting residents). As a result, HCFA has demanded that BQA provide it with additional information on the use and prevalence of single task employees in Wisconsin facilities.

NOTE: BQA disagrees with HCFA’s interpretation of federal law and intends to challenge that interpretation in order to continue Wisconsin’s current practice.

Supporting Arguments:

Today, in Wisconsin’s long-term care facilities, “single task” employees are providing invaluable services to the frail elderly and disabled persons entrusted to the care of those facilities. Every day, these caring individuals make a difference in the lives of those individuals: The difference between a nutritious meal served with dignity by a person who has time to share, time to care and time to converse, or a meal that is simply served. If you or your loved one were the resident, which would you prefer?

The Wisconsin Association of Homes and Services for the Aging (WAHSA) is a statewide membership organization of not-for-profit corporations principally serving elderly and disabled persons. Membership is comprised of 190 religious, fraternal, private and governmental organizations which own, operate and/or sponsor 194 not-for-profit nursing homes, 71 community-based residential facilities, 39 residential care apartment complexes, 100 independent living facilities, and 446 community service programs which provide services ranging from Alzheimer's support, child day care, hospice and home care to Meals on Wheels. For more information, please contact the WAHSA staff at (608) 255-7060: John Sauer, Executive Director; Tom Ramsey, Director of Government Relations; or Brian Schoeneck, Financial Services Director.

WAHSA 204 South Hamilton Street Madison, WI 53703
Telephone: (608)255-7060 FAX:(608)255-7064