For California assisted living providers caring for individuals with traumatic brain injury (TBI), finding clear information about staff training requirements can be challenging. The requirements are contained within California’s Medi-Cal Assisted Living Waiver (ALW) rather than in a stand-alone TBI training regulation.
One requirement is particularly important for providers:
Under the ALW Residential Habilitation service, staff providing these specialized services must have a minimum of two hours of documented approved education specific to TBI and a minimum of two hours of documented approved continuing education each year thereafter (California Department of Health Care Services [DHCS], 2024).
For Residential Care Facilities for the Elderly (RCFEs) and other ALW providers serving individuals with TBI, understanding this requirement is an important part of preparing staff to meet residents’ complex needs.
Providers looking for education to support this requirement can learn more about CareerSmart® Learning’s California ALW TBI Training Package, which includes 2.25 hours of online TBI-focused education.
Understanding the California Assisted Living Waiver
California’s Assisted Living Waiver is a Home and Community-Based Services program that gives eligible Medi-Cal beneficiaries who require nursing-facility-level care an opportunity to receive services in an assisted living or other approved community setting rather than a nursing facility.
The current five-year waiver term is approved from March 1, 2024, through February 28, 2029, and the program currently operates in 15 California counties (DHCS, n.d.-a).
Assisted Living Services are organized into five tiers based on participants’ needs. Tier 5 is specifically intended for individuals with severe TBI who require intensive assistance with activities of daily living (ADLs) and instrumental activities of daily living (IADLs), as well as additional Residential Habilitation services (DHCS, 2024).
Tier 5 participants may have significant physical, behavioral, cognitive, communication, social, and psychosocial needs. California’s waiver criteria identify concerns that may include:
- Severe mental or cognitive disabilities
- Wandering or flight behavior
- Inconsistent ability to provide self-care
- Potential for injury to self or others
- Behavioral outbursts that negatively affect others
- Previous unsuccessful community placements
- Potential need for 24-hour, seven-day-a-week hands-on or physical-presence supervision and management (DHCS, 2024)
These characteristics help explain why TBI-specific staff education is important. Providing staff with TBI-focused education for ALW Residential Habilitation services can help them better understand the physical, cognitive, behavioral, and psychosocial challenges that may follow a traumatic brain injury.
What TBI Training Does California Require?
Residential Habilitation is designed to provide additional support for participants whose needs require more intensive staff attention and specialized behavioral approaches than would ordinarily be provided through routine Assisted Living Services.
For facility staff providing this service, the waiver establishes the following TBI education requirements:
- Initial TBI Education:
A minimum of two hours of documented approved education specific to traumatic brain injury.
- Annual TBI Continuing Education:
A minimum of two hours of documented approved continuing education each year thereafter (DHCS, 2024).
Residential Habilitation also requires prior DHCS approval and is intended to provide additional, appropriate staffing based on an individual participant’s needs (DHCS, 2024).
CareerSmart® Learning offers 2.25 hours of online California ALW TBI training through two self-paced brain injury courses, with individual certificates of completion for training documentation.
Importance of TBI Education
TBI education should help staff understand not only what traumatic brain injury is, but also how brain injury can affect everyday functioning.
A person with TBI may experience changes in:
- Memory and information processing
- Attention and concentration
- Executive functioning
- Judgment and impulse control
- Communication
- Emotional regulation
- Behavior
- Ability to complete ADLs safely and independently
These effects may not always be obvious. For example, a resident who becomes frustrated when given several directions at once may not be intentionally resisting care. The resident may be experiencing slowed information processing or cognitive overload related to the brain injury.
Understanding TBI can help staff consider what may be contributing to a behavior and respond in a more informed, person-centered manner.
How Is This Different From Regular RCFE Staff Training?
California already requires substantial training for many RCFE direct-care employees.
Under California Health and Safety Code § 1569.625, RCFE staff who assist residents with personal activities of daily living generally receive 40 hours of initial training. Twenty hours must be completed before working independently with residents, with the remaining 20 hours completed within the first four weeks of employment. Applicable staff must also receive 20 hours of training annually (California Legislative Information, n.d.).
Required subject areas include physical limitations and needs of older adults, personal care, residents’ rights, medication policies and procedures, psychosocial needs, emergency response, dementia care, person-centered approaches, and cultural competency (California Legislative Information, n.d.).
The ALW Residential Habilitation requirement is different because it specifically requires applicable staff to receive TBI-focused education (DHCS, 2024).
What Should California Providers Do Next?
RCFEs and other providers participating in California’s Assisted Living Waiver should determine whether they provide Residential Habilitation services and identify staff members to whom the TBI-specific education requirement applies.
Providers should review whether applicable staff have:
- Completed the required initial TBI education
- Received the required annual TBI continuing education
- Appropriate documentation of completed education
- Education that prepares them for the needs of the TBI population they serve
A Prepared Workforce Matters
California’s Assisted Living Waiver provides an important community-based option for people with severe traumatic brain injuries who might otherwise require institutional care. But successful community placement requires more than an available bed, it requires staff who understand the individuals they are supporting.
For providers furnishing Residential Habilitation services, TBI education for staff is not only relevant to quality care but also a requirement under the California waiver.
CareerSmart® Learning is committed to helping healthcare and residential care professionals strengthen their understanding of traumatic brain injury and better prepare for the complex needs of the people they serve.
Need TBI Education for Your ALW Staff?
CareerSmart® Learning’s California ALW TBI Training Package combines two self-paced courses for 2.25 hours of TBI-focused education.
References
California Department of Health Care Services. (2024). Application for a §1915(c) Home and Community-Based Services waiver: CA.0431.R04.02. California Health & Human Services Agency.
California Department of Health Care Services. (n.d.-a). Assisted Living Waiver. California Health & Human Services Agency.
California Legislative Information. (n.d.). California Health and Safety Code § 1569.625. State of California.
