Opinion: Suspension of Professional Certification Requirements for CNAs (AFL 20-35.7)

Updated: Mar 21

Here is Clearpol’s opinion on AFL 20-35.7, which can be found on our Policies.ai website here alongside the AFL text:


AFL 20-35.7 supersedes AFL 20-35.6 and extends to 6/30/2022 the temporary waiver of specified statutory and regulatory requirements for CNAs due to the state of emergency related to the COVID-19 outbreak, in compliance with Executive Order N-12-21. This revision informs applicants and certificate holders how to obtain/maintain an active/employable status after the expiration of the listed waivers. This applies to the waivers for initial CNA certification, renewal and expiration.

A nurse assistant (NA) enrolled in an approved certification training program may continue to be employed for more than 3 months after the start date of employment but is encouraged to complete the program as training programs resume. A NA who has not completed the training program shall only render services at the competency level confirmed by the training program on a competency checklist to be shared with the facility. All nurse assistants employed under this waiver must complete the initial certification program to continue to provide care.

All CNAs in an active status are encouraged to renew following normal timelines. A CNA seeking certificate renewal may complete any of the 48 required hours of in-service or CEUs at any time during the 2-year recertification period and may complete all of the required 48 hours through online or distance learning formats. All CNAs with an existing waiver must complete in-service and continuing education requirements and renew their certification to continue providing care. CDPH encourages submission of renewal applications well in advance of the waiver expiring.

A CNA whose certification expired no earlier than 3/30/2018, or whose certification will expire during the state of emergency, and who remains in an "employable during state of emergency" status may work as a CNA without renewal.


All facilities must check CDPH's online verification page http://cvl.cdph.ca.gov/SearchPage.aspx to verify employment eligibility. Only those CNAs with a status of "active" or "employable during state of emergency" may be employed. A CNA who remains in an "employable during state of emergency" status will be allowed to complete in-service or CEUs and count them towards renewal of the certification. Any of the 48 hours of in-service and continuing education may be completed through online or distance learning formats. CNA's employed under this waiver must renew their certification to continue providing care

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