Texas Caregiver Training Requirements 2026: What HCSSA PAS Agencies Must Know

For a new HCSSA agency in Texas, caregiver training compliance sits right at the intersection of "required before you open" and "reviewed every time a surveyor visits." Getting it right from the start matters — not because the requirements are difficult, but because the documentation errors are.

This guide covers what Texas law requires for PAS (Personal Assistance Services) caregiver training, what HHSC surveyors specifically look for, and where agencies run into problems. All requirements reference the governing regulation: Texas Administrative Code Title 26, Part 1, Chapter 558.

Information is current as of July 2026.

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Two Different Rule Sets: PAS vs. Home Health

Before anything else, one distinction is worth stating clearly because it causes a lot of compliance confusion:

PAS caregivers are not home health aides. And the training rules are different.

Texas HHSC licenses agencies under Chapter 558 in two primary categories: Personal Assistance Services (PAS) and Home Health. Each category operates under different regulatory requirements for caregiver training.

The 12-hour annual continuing education rule — the one you'll hear cited most often when people discuss caregiver training in Texas — applies to Home Health Aides licensed under the home health framework. Many PAS agency administrators incorrectly adopt this rule for their own caregivers, either because they've heard it in passing or because their policy templates were written for a different license type.

PAS attendants are regulated under 26 TAC §558.404 (PAS-specific standards) and the general staffing requirements in §558.245. The annual training obligation for PAS attendants is not the same 12-hour HHA requirement. The orientation training requirement, however, is specific and enforceable — and that's where most agencies need to focus.

This guide covers the PAS framework. Agencies holding a Licensed Home Health or Licensed and Certified Home Health license should confirm their caregiver training requirements separately under those regulatory sections.

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Attendant Orientation: The Baseline Requirement

The most important training requirement for PAS agencies is this: every attendant must receive orientation before providing services to any client.

This is not a "within 30 days" rule. It is a "before the first visit" rule. An attendant who has not completed orientation cannot be sent to a client's home. Period.

The requirement is in 26 TAC §558.404 (Standards Specific to Agencies Licensed to Provide Personal Assistance Services) and §558.245 (Staffing Policies). HHSC surveyors treat this as a hard line — if an attendant was sent to a client before orientation was documented as complete, that is a citation regardless of how good the attendant is or how long they've worked in home care.

The orientation must be conducted by or under the direction of a supervisor, and the completion must be documented in the attendant's personnel file before they begin work with clients.

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What Orientation Must Cover

The Texas TAC specifies the topics that attendant orientation must address for PAS agencies. The required scope includes:

Professionalism and role boundaries

• The scope of the attendant's role in the client's home
• Professional conduct, boundaries, and agency expectations
• Client privacy and confidentiality

Client rights

• The attendant's obligation to protect and uphold client rights under HHSC policy and Chapter 558
• How to respond when a client's rights appear to be at risk

Abuse, neglect, and exploitation (ANE)

• Definitions of abuse, neglect, and exploitation as recognized by Texas law
• The attendant's mandatory reporting obligation — all HCSSA employees are mandatory reporters under Texas law
• Who to report to (HHSC's Long-term Care Regulatory unit; 1-800-458-9858 for complaints)
• What not to do: no retaliation for reporting; no internal resolution of suspected ANE without regulatory notification

Providing care in a client's home

• Differences between institutional care and home-based care environments
• Safety awareness in a home setting versus a clinical facility
• Understanding the client's care plan and following it accurately

Assisting with activities of daily living (ADLs) and instrumental ADLs (iADLs)

• Personal hygiene assistance (bathing, grooming, dressing, toileting)
• Meal preparation and feeding assistance
• Mobility support — assisting with transfers, positioning, and ambulation within the home
• Homemaker tasks (laundry, light housekeeping, errands)

Ambulation and transfer techniques

• Body mechanics for safe transfers to protect both caregiver and client
• Gait belt use and fall prevention practices
• Recognizing when a transfer situation exceeds the attendant's scope

Medication self-administration assistance

• The distinction between assisting a client with self-administration versus administering medications (PAS attendants may assist; they do not administer)
• Medication safety practices and what to document

Range of motion and positioning

• Passive range of motion techniques for clients with limited mobility
• Proper positioning for seated and bedridden clients to prevent pressure injuries

Infection control

• Standard precautions in the home care environment
• Hand hygiene protocols (the most important infection control measure in home care)
• Bloodborne pathogen exposure procedures
• Tuberculosis (TB) awareness and symptom recognition

Safety and emergencies in the home

• Emergency procedures and when to call 911
• Fire and disaster safety in a residential environment
• Reporting accidents and incidents
• Environmental hazards common in home settings

Working with clients with challenging behaviors

• Communication techniques for clients with dementia or cognitive impairment
• De-escalation approaches
• When to contact a supervisor

The full topic list is substantial. Most compliance-grade Texas PAS orientation programs run 8 to 12 hours to cover all required areas with sufficient depth. Agencies that use placeholder orientation programs covering three or four topics are not in compliance regardless of the hours shown on the certificate.

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Annual In-Service Training for PAS Attendants

Here is the accurate picture, which differs from what many agency owners are told:

TAC Chapter 558 does not impose a specific clock-hour annual in-service requirement on PAS attendants the way Chapter 97 imposes a 12-hour annual requirement on Home Health Aides. PAS agencies are required to document ongoing training consistent with their written staffing policies and HHSC survey expectations, but the number of hours is not prescribed by TAC rule in the same way.

In practice, what HHSC surveys assess is:

1. Does the agency have a written policy describing its ongoing training program? This is reviewed as part of the agency's written policies and procedures.
2. Are the topics most relevant to infection control, client safety, and ANE reporting being revisited annually? Surveyors often ask attendants if they have received recent training on these areas.
3. Is there documentation of the training in each employee's personnel file? Training that happened but wasn't documented is treated the same as training that didn't happen.

Recommended minimum annual in-service topics for Texas PAS agencies:

• Infection control updates (always current — new guidelines emerge)
• Abuse, neglect, and exploitation reporting refresher
• Client rights
• Emergency procedures review
• Any policy or procedure changes implemented in the past year

A practical approach: agencies that conduct one documented 2-hour annual in-service training session per attendant — with a sign-in sheet and topic outline filed in each personnel record — are typically in good shape for survey. This is not a regulatory minimum; it's a documented defensible position.

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Background Checks: Required Before the First Visit

Background screening for PAS caregivers in Texas operates under multiple overlapping requirements. All must be completed before an attendant begins working with clients.

1. Criminal History Check — Texas DPS Fingerprinting

All new employees who will have direct contact with clients must submit to a criminal history check through the Texas Department of Public Safety (DPS) fingerprinting program. This is not a basic background check run through a third-party service — it is the Texas DPS Fingerprint-Based Applicant Clearinghouse of Texas (FACT) system.

HHSC requires agencies to use the FACT system for criminal history background checks for client-contact staff. The fingerprinting appointment can take time to schedule; factor this into your hiring timeline so an attendant isn't cleared to work before the check is complete.

2. Nurse Aide Registry (NAR) Search

The Nurse Aide Registry tracks individuals who have been found to have committed abuse, neglect, exploitation, or misappropriation against residents or consumers in regulated settings. HCSSA agencies must search the NAR for every new hire before employment and repeat this check annually for all active employees.

An individual listed on the NAR as "unemployable" cannot be hired for client-contact work under any HCSSA agency.

The NAR can be searched through HHSC's online Employability Status Check (ESC) portal.

3. Employee Misconduct Registry (EMR) Search

The Employee Misconduct Registry tracks individuals found to have committed misconduct (a broader category than abuse or neglect) in HHSC-regulated settings. Like the NAR, the EMR must be searched before hire and annually thereafter.

An individual listed on the EMR as unemployable is ineligible for client-contact employment. The EMR is also searched via the HHSC Employability Status Check portal — both registries can be checked simultaneously in the same search.

4. OIG Exclusion Check (Medicaid-Billing Agencies)

Agencies that bill Medicaid programs (STAR+PLUS, PHC, CAS, or other Medicaid-funded services) have an additional federal obligation: checking the HHS Office of Inspector General (OIG) List of Excluded Individuals and Entities (LEIE) before hire and monthly thereafter for all employees who could affect Medicaid billing. Hiring an excluded individual and billing Medicaid for their services results in federal liability.

The OIG LEIE search is free at oig.hhs.gov/exclusions.

Annual Rechecks

NAR and EMR checks are not one-time events. HHSC requires agencies to recheck all active client-contact employees against both registries on an annual basis. Most agencies conduct these annual rechecks as part of their anniversary-date HR review or calendar-year compliance sweep. The annual check date and result must be documented in each employee's personnel file.

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TB and Infection Control Screening

HCSSA agencies are required to maintain infection control policies and procedures under 26 TAC §558.245. As part of these policies, most agencies require new employees to demonstrate freedom from active tuberculosis before beginning client contact.

Standard practice (and HHSC survey expectation) is a TB skin test (TST) or interferon-gamma release assay (IGRA) within the past 12 months at the time of hire, or a symptom screening questionnaire for employees who have had a documented positive TB test history and converted to annual symptom screening. Positive TB test results require medical clearance before the employee begins client contact work.

While the specific TB screening requirement is part of the agency's infection control policy rather than a standalone TAC requirement with its own section, HHSC surveyors review infection control policies and documentation during every survey. Agencies without documented TB screening for their caregivers receive deficiency citations under their infection control policy obligations.

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What HHSC Surveyors Look for in Personnel Files

Understanding the survey process helps agencies set up documentation correctly from the start, rather than scrambling to create records retroactively.

During every HHSC survey of an HCSSA agency, surveyors request a sample of caregiver personnel files. They review:

Pre-employment documentation:

• Completed application with employment history
• Criminal history check documentation (FACT/DPS confirmation)
• NAR search result (date and printed output or screenshot)
• EMR search result (same)
• TB screening documentation (test date, result)
• Signed acknowledgment of client rights and mandatory reporting obligations

Training documentation:

• Orientation completion certificate or record with date and topics covered
• Documentation that orientation was completed before the first client visit
• Annual in-service training records (dates, topics, signatures)

Annual re-checks:

• NAR annual recheck date and result
• EMR annual recheck date and result

A missing or incomplete item in any of these areas is a deficiency. The most common deficiencies HHSC cites in personnel files:

• Orientation completion records missing or undated
• No documentation that orientation occurred before the first visit date
• NAR/EMR checks not completed annually (or no record of annual checks)
• Annual in-service training documented for some employees but not all

The practical fix is a consistent personnel file checklist that every new hire's file is checked against before the first visit — and an annual compliance review that ensures all active employees have current documentation.

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Administrator Training: A Reminder

For agencies new to HCSSA licensing, caregiver training is separate from administrator training requirements. Administrator and alternate administrator training — 8 hours before designation, 16 additional hours in the first 12 months, plus 12 hours annually thereafter — is required under 26 TAC §558.259 and §558.260.

A full breakdown of administrator qualification requirements and training timelines is in the Texas HCSSA Licensing Guide.

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How Home Care Software Helps with Training Compliance

Most compliance errors in caregiver training don't happen because agencies don't know the rules — they happen because tracking orientation completion, background check dates, and annual re-checks manually across 20, 40, or 80 employees creates gaps that aren't visible until a surveyor finds them.

A home care software platform that includes caregiver records management makes this tractable:

• Orientation tracking: Record orientation completion date and mark the attendant as eligible for client visits only after that date is logged
• Background check history: Store NAR/EMR search dates and flag when annual rechecks are coming due
• Training expiration alerts: Get notified before an annual in-service deadline passes rather than discovering a gap during a survey
• Document storage: Upload signed orientations, training certificates, and TB screening results to each caregiver profile so records are accessible without paper file searches

For small Texas agencies managing the full compliance load with a lean staff, having this built into the same platform as scheduling means the person scheduling the visit and the person managing the caregiver record are looking at the same system — and the scheduling system won't let an un-oriented caregiver be assigned to a client.

Atlas Care Software for Texas Agencies →

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Texas PAS Caregiver Training Compliance Checklist 2026

Use this as a pre-employment checklist for every new PAS attendant.

Before the first client visit:

• Criminal history check submitted through Texas DPS FACT system; result received
• NAR search completed (date and result documented); no unemployable finding
• EMR search completed (date and result documented); no unemployable finding
• OIG exclusion check completed (if agency bills Medicaid)
• TB screening completed; result documented (or symptom screening questionnaire if applicable)
• Orientation completed — all required topics covered; certificate or record with date in file
• Signed acknowledgment of client rights in file
• Signed acknowledgment of mandatory reporting obligation in file

Annual maintenance (all active employees):

• NAR annual recheck completed and documented
• EMR annual recheck completed and documented
• OIG exclusion monthly check current (Medicaid-billing agencies)
• Annual in-service training completed and documented; topics include infection control, ANE reporting, and policy updates

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Additional Resources

• HHSC HCSSA Licensing Unit: 512-438-2630
• HHSC Employability Status Check (NAR + EMR search): hhs.texas.gov/long-term-care-credentialing
• OIG LEIE Exclusion Search: oig.hhs.gov/exclusions
• Texas DPS FACT Background Check: texas.gov/fingerprint
• Texas Administrative Code Chapter 558: texreg.sos.state.tx.us
• ANE Complaint and Reporting Line: 1-800-458-9858

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Related Guides

• Texas HCSSA License Requirements 2026 — step-by-step application guide including administrator qualification standards and the pre-survey CBT
• Texas EVV Requirements 2026 — electronic visit verification requirements, the HHAeXchange aggregator, and the 2025–2028 alternative device phase-out
• How to Get Your First STAR+PLUS Client — the TMHP enrollment and MCO credentialing sequence for newly licensed PAS agencies
• STAR+PLUS Billing for Texas Home Care Agencies — billing workflows, service codes, and common denial reasons
• Compare Home Care Software → — see how Atlas compares to AxisCare, Axxess, WellSky, and other platforms on caregiver management and compliance tracking