Key Points
- Training sites now include hospitals and vocational settings, not just nursing homes.
- Remote written exams and skills tests are allowed with state approval.
- Employed CNAs cannot be charged fees and may get reimbursed within 12 months.
How the New CMS Flexibilities Can Speed Up Your CNA Certification
Discover what the policy change means for your training—cost savings, more locations, remote exams, and a faster path to becoming a CNA.
For years, the path to CNA certification was a tightrope between upfront costs and inflexible training schedules. The April 2026 CMS memo QSO-26-08-NH1 rewrites that equation by forbidding facilities from charging employed aides for training or testing, expanding eligible training sites to hospitals and vocational centers, and permitting remote exam options. These shifts target the industry’s persistent staffing shortages by removing financial and logistical barriers that kept qualified candidates out. What was once a rigid, location-bound process now adapts to the student’s circumstances, not the other way around.
What Is the 2026 CMS Memo on CNA Training?
On April 14, 2026, the Centers for Medicare & Medicaid Services (CMS) released memo QSO-26-08-NH1, a document that directly affects how CNA training and competency evaluation programs operate across the country. For anyone pursuing a CNA certification, this memo signals a shift toward more accessible training options, while keeping the quality of education intact.
A Memo Designed to Strengthen the CNA Workforce
The primary goal of the memo is to address persistent staffing shortages in nursing homes by making CNA training more flexible and affordable. It recognizes that many qualified individuals face barriers such as high upfront costs, limited training locations, or rigid exam requirements. By reducing these obstacles, CMS aims to expand the pipeline of certified nursing assistants ready to serve in long-term care and other healthcare settings.
Flexibilities Without Lowering Standards
Importantly, the memo does not change the core requirements: you must still complete at least 75 hours of training, including 16 hours of supervised practical experience. Instead, it introduces new options for where training can happen, who can instruct, and how exams can be administered. For example, training can now take place in hospitals or vocational schools, not just nursing homes. Remote written exams and observed skills demonstrations are possible if state rules allow. The memo also strengthens employer sponsored cna training protections, clarifying that facilities cannot charge employed or soon-to-be-employed trainees for training-related costs, and may reimburse expenses incurred within the past 12 months. These updates focus on how you access the pathway, not the destination itself. Your certification still depends on mastering the same essential skills.
The new CMS memo slashes old obstacles: cost, location, and rigid testing. Now, you can train where it suits you, take tests remotely, and avoid upfront fees, putting a CNA career truly within reach.
Key Flexibilities That Change CNA Training
On April 14, 2026, CMS issued QSO-26-08-NH, a memo that updates Nurse Aide Training and Competency Evaluation Program (NATCEP) rules.1 The changes create more flexible pathways for CNA certification without lowering quality. Key flexibilities include:
- Training locations: You can now complete your training in nursing homes, hospitals (via hospital CNA training partnerships), or vocational settings, not just long-term care facilities.
- Instructor qualifications: RNs or LPNs with experience or training in teaching adults can now lead courses, expanding the pool of available educators.
- Remote testing and observation: If your state approves, written exams and skills demonstrations (covering essential CNA clinical skills) may be offered remotely, with safeguards for resident consent and safety.
- Financial protections: Facilities cannot charge you for training, materials, testing, or registry fees if you’re employed or have a job offer. You may also be eligible for reimbursement of these costs within 12 months of finishing your program.
These flexibilities are designed to remove common barriers to entry, such as limited training locations, instructor shortages, and upfront costs. However, adoption varies by state, and not every flexibility is available everywhere yet. We’ll cover state-level updates in a later section.
Questions to Ask Yourself
Are you currently employed or have a job offer at a facility that can sponsor training?
If a nursing home or hospital is already invested in your employment, you may qualify for free or reimbursed training. This removes a major financial barrier and speeds up your entry into the workforce.
Do you live near a hospital that offers CNA training?
With the new memo, hospitals are now approved training sites, not just long-term care facilities. Proximity to a hospital program could mean shorter commutes and more scheduling options.
Would remote testing fit your learning style and technology access?
Remote written exams and video-observed skills tests require a reliable computer, internet, and a quiet space. If you struggle with tech or focus better in person, an on-site test might yield stronger results.
What Stays the Same: Training Hours and Clinical Requirements
Despite the new flexibilities, the core training standards that define a competent certified nursing assistant remain firmly in place.
Minimum Training Hours Are Unchanged
The federal standard established by CMS still requires at least 75 total hours of instruction, including 16 hours of hands-on supervised practical training. This baseline has not been lowered. The memo underscores that these minimums are the floor, not the ceiling. States remain free to set more rigorous standards. Many states already adopt higher thresholds, so always check with your state’s nurse aide registry.
Supervised Clinical Practice Is Still Required
While the memo allows more flexibility in where and how training is delivered, it does not compromise on quality of care. The 16-hour clinical component must still be supervised by a qualified instructor, whether in a nursing home, hospital, or vocational setting. Students must demonstrate their skills in person or through state-approved remote observation arrangements that protect resident safety and privacy. Online learning can cover the classroom portion, but you will still need to prove your ability to provide safe, effective care before certification. This ensures that every new CNA enters the workforce with a verified set of clinical competencies.
Financial Protections: No Fees and Reimbursement Options
The 2026 CMS memo establishes a 12-month window for CNAs to recover training costs they've already paid, and it forbids facilities from charging newly hired or employed aides for any certification expenses.1 If you are employed by or have an offer of employment from a Medicare/Medicaid-certified nursing facility on the first day of your nurse aide training (NATCEP/CEP), the facility must cover all related costs: tuition, textbooks, competency testing, and state registry listing fees.1
No More Out-of-Pocket Costs for Employed CNAs
Effective immediately, facilities cannot pass training expenses on to you. Whether you complete your clinical hours in a nursing home, hospital, or vocational setting, the prohibition holds.1 This applies to both initial training and any past training you completed within the last 12 months, as long as you now have an employment relationship.
How to Claim Reimbursement Within 12 Months
If you’ve already paid for your CNA training and then secured your first CNA job, you can request reimbursement.1 Gather proof of training completion (certificate or transcript), itemized receipts for costs, your employment offer letter, and a government-issued ID. Submit these to your employer or, in some states, directly to the state Medicaid agency.1 Reimbursement may be prorated based on your length of service, so file promptly.1 The 12‑month clock starts from your training completion date, not your hire date.1
Remote Vs. In-Person Testing: Weighing Your Options
The 2026 CMS memo introduces remote options for the written competency exam and skills observation, offering new flexibility for aspiring CNAs. While these changes can streamline certification, they also require careful consideration of technology needs and state approvals.
Pros
- Remote written exams let you test from home, eliminating travel and making it easier to schedule around work or family commitments.
- Remote skills observation can feel less stressful when performed in a familiar setting, and instructors can assess you under general supervision without being in the same room.
- These options can increase access for students in rural areas or those with limited transportation.
Cons
- Remote testing demands a stable internet connection and a private, quiet environment, which may be challenging for some students to secure.
- Skills observation via video requires clear camera positioning and resident consent, adding steps that can delay the process.
- State approvals vary, so not every program will offer remote testing, and you may need to verify availability in your area.
Real-World Examples: Programs Already Using These Flexibilities
In the months since CMS released its training flexibility memo1, states and providers have moved quickly to adapt their CNA programs. Several initiatives now showcase how the new rules translate into real-world opportunities for students.
- Wisconsin's WisCaregiver CNA Program is a state-sponsored effort offering free training and testing for individuals employed by or hired at participating nursing homes. This directly aligns with the memo's prohibition on charging CNAs and its reimbursement pathway. In response to the new flexibility, the program now includes hospital-based clinical rotations, giving students experience beyond traditional nursing home environments.
- Massachusetts Consolidated CNA Credential launched in mid-2026, updating the state's curriculum to allow clinical training in hospitals and vocational settings, not just long-term care facilities. This change mirrors the memo's location flexibility and is designed to speed up class availability. State officials have noted strong early interest in the new program.
- Cinematic Health ReadyCNA is an online platform adopted by many nursing homes to deliver didactic coursework remotely. Under the memo's remote testing provisions, it enables live video observation of skills by an RN, eliminating travel and scheduling barriers. Providers using the platform note that it helps them integrate training into busy facility schedules while maintaining quality oversight.
These examples are just a few of the emerging cna training stories showing how the CMS flexibilities are already reshaping CNA training into a more accessible and affordable pathway.
How to Take Advantage of These Flexibilities
Instead of waiting for a traditional program in a single facility type, forward-thinking students are leveraging a broader landscape of training sites, remote exam possibilities, and employer-backed funding.
Find Flexible Training Programs
Start by visiting your state nurse aide registry website or health department portal to search for approved CNA programs. The 2026 CMS memo expands eligible settings to nursing homes, hospitals, and vocational schools, no longer limited to long-term care facilities.1 If a local employer offers training, ask about enrollment directly. Some programs blend classroom and clinical hours across multiple locations; don't hesitate to ask about schedule and site flexibility.
Ask About Remote Testing and Costs
Before you commit, ask about CNA testing options, including remote exams. Some states now permit written exams and skills observation via video, provided resident consent and safety standards are met. Also, ask potential employers upfront: “Do you reimburse training, materials, and exam fees?” The memo states that facilities cannot charge you for these if you are employed or have a job offer.1 Even if you initially pay, reimbursement may be possible if you gain employment within 12 months, so clarify the process early.
Secure Reimbursement and Keep Records
Keep all receipts, proof of completion, and any correspondence. You have up to 12 months after finishing to submit a reimbursement claim. Always verify your state’s adoption of these flexibilities with the nurse aide registry, a state-by-state table below summarizes current statuses, but rules can shift, so call or check the registry website before you start. Documentation is your key to reducing or eliminating out-of-pocket costs.
State-By-State Adoption: What to Watch For
Which states have adopted the 2026 CMS CNA training flexibilities, and how can you find out if yours is one of them?
As of August 2026, only Massachusetts has formally embraced one of the new flexibilities: expanded training sites beyond nursing homes.1 The state now allows CNA training in hospitals and vocational settings. However, Massachusetts has not yet confirmed whether it will permit remote testing or implement fee reimbursement for trainees.
For most other states, including California, Texas, Florida, New York, and Michigan, adoption status remains unconfirmed. No public announcements have been made regarding remote testing, expanded training locations, or financial protections like fee waivers.2 That doesn’t mean these options are off the table; the CMS memo is permission-based.3 States have the authority to opt in, but each will move at its own pace.
Prospective CNAs should monitor announcements from their state’s department of health or nursing board. You can also use cnaclasses.org to search for programs that may already be taking advantage of these flexibilities at the local level. Because adoption is decentralized, staying informed about your state’s decisions is essential to maximizing the benefits of the new rules.
Related Articles
CNA Salary at a Glance
Career Outlook and Salary for CNAs in 2026
Understanding the CNA salary and job outlook for 2026 helps you make informed decisions about entering the field. Rather than relying on outdated or incomplete CNA career information, it is important to consult authoritative sources that publish current data. The Bureau of Labor Statistics (BLS.gov) is the go-to government resource for wage estimates, job growth projections, and employment trends nationally and by state. You can search for nursing assistants under SOC code 31-1131 to find the latest figures. Professional associations such as the American Health Care Association (AHCA) and state nursing board websites often provide additional context on local demand and regulatory changes that affect the workforce.
Many CNA training programs and community colleges share graduate employment data on their websites. These program-specific insights can give you a clearer picture of job placement rates and typical starting salaries in your area. Keep in mind that wages vary widely depending on factors such as geographic location, years of experience, and the type of facility where you work. Nursing homes, hospitals, and home health agencies may offer different salary ranges and benefits.
For the most accurate career outlook, focus on state-level projections, as healthcare demand is shaped by local demographics and policy. By cross-referencing government data with real-world feedback from training providers and professional organizations, you can build a realistic view of where a CNA career can take you. Taking the time to research these sources now positions you to enter a field with strong demand and opportunities for advancement through CNA to RN programs.
Frequently Asked Questions About the CMS CNA Training Memo
The 2026 CMS memo on CNA training introduces key flexibilities, but it also raises many questions. Here are straightforward answers to help you navigate the new rules on costs, locations, testing, and state adoption.
The CMS memo on CNA training flexibilities (April 2026) clarifies nurse aide training requirements and introduces flexibilities to boost access. It allows training in more settings, remote testing options, and financial protections like fee prohibitions and reimbursements for eligible CNAs.
Yes, if you were employed or had a job offer from a facility at training start, you can request reimbursement for training, materials, testing, and registry fees within 12 months of program completion.2 Check with your employer or facility for details.
Training locations now include nursing homes, hospitals, vocational schools, and other approved clinical sites, not just long-term care facilities.2 This gives you more convenience and access while still meeting the required supervised clinical hours.
The minimum remains 75 total hours, with at least 16 hours of supervised practical training.2 These federal standards ensure you develop the knowledge and hands-on skills needed to provide safe care.
The memo does not approve fully online CNA courses, but states can allow remote written exams and skills observation.2 In-person clinical hours remain mandatory. Check with your state for remote testing availability.
Adoption varies by state. Check your state’s health department or nursing board website for updates. You can also email CMS at [email protected]2 or AHCA at [email protected] for assistance.
If you're employed or have a facility job offer at training start, no fees can be charged for training, materials, testing, or registry.2 You may also get reimbursed for prior costs within 12 months of completion.
