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Managing HHSC Training Mandates

Feb 2, 2021



TAC 448.603(c) requires that prior to performing their duties and responsibilities, the facility provide and orientation to newly hired staff, volunteers, and students. This orientation shall include information addressing:

  • TCADA rules;
  • facility policies and procedures;
  • client rights;
  • client grievance procedures;
  • confidentiality of client-identifying information (42 C.F.R. pt. 2; HIPAA);
  • standards of conduct; and
  • emergency and evacuation

Although not implicitly stated in the rules, HHSC licensure division, in recent inspections, has required that this orientation be specific to the agency. To address this issue, BHC has revised the certificate to reflect the most recent interpretation of this regulation. Moreover, we recommend that as part of orienting your employees to the agency, you meet with them in person to discuss these topics and provide them with an employee handbook, client handbook, information on accessing agency policy and procedure and information on accessing Texas Administrative Code Chapter 448.


HHSC has issued a Guidance Letter (GL 20-3007) dated July 31, 2020, this guidance letter states that Abuse, Neglect & Exploitation may be provided in a live, interactive, instructor-led, electronic or face-to- face. The guidance letter specifically states that “he emergency amendments to §448.603, Training, are adopted under Texas Administrative Code Title 25 (25 TAC), Part 1, Chapter 448, Subchapter F. Under these emergency rule amendments, CDTFs may temporarily provide training related to ANE and NVCI to staff through live, interactive, instructor-led, electronic means performed using synchronous audiovisual interaction. The remainder of §448.603 remains unchanged. CDTFs must follow all other staff training requirements when providing ANE and NVCI training under these emergency rule amendments.” This mean that until amended agencies may provide ANE and NVCI using web-based tools, with audiovisual synchronous interaction. Residential treatment programs must provide 8 (eight) hours of ANE and 4 (four) hours of NVCI training within 90 day of hire and annual thereafter. Outpatient treatment programs must provide 2 (two) hours of ANE and 4 (four) hours of NVCI of training within 90 day of hire and annual thereafter.


In addition to the above requirements, this also must be done by a NVCI certified instructor or someone with documented experience in NVCI. We recommend that you send a staff for formal training in NVCI or document a senior staff with experience to conduct the initial face to face training. Please contact us if you would like a referral for cost effective instructor training.

We have in service documents training documents you can use in the ADMIN HELP DOCS LIBRARY. Keep an in-service sign in sheet for licensure to review when you are inspected. We encourage you to use these documents for all of your training activities.


There are three options to meet the face-to-face training mandates by Texas Health and Human Service Commission. This only applies to addiction treatment facilities licensed by Texas Health and Human Service Commission.

Facility Initiated Face to Face Training– Facilities can conduct training by qualified staff/employees or hire external training professionals to complete initial and ongoing training. The company must have documentation of the employee conducting training experience/expertise.

Remote Synchronous Classroom Training– Company can utilize live synchronous classroom of BHC or others. These must be live, include live interactive options, and must be recorded. This option was made available after COVID. It is uncertain if will be allowed to continue past COVID disaster declarations.

Send Employees to External Training– The company can send students for training at conferences and seminars for NVCI and ANE.

Regardless of what options selected, we recommend that companies have employees complete the online course in-service supplements for Abuse, Neglect and Exploitation and Non-Violent Crisis Intervention. This is a mechanism to protect companies in liability claims.

We recommend the following as a cost-effective way for managing these requirements:

  1. All employees complete online supplement training
  2. Current employees- Incorporate a month in service that included training related to abuse and neglect and NVCI. We have an “Inservice Packet” in the administrative
  3. New employees- Complete live, synchronous, remote

As a final option, have all current employees complete one time annual training for ANE and NVCI, you can bring someone in or use our webinar.


We have provided you with the following support documents in the ADMIN PORTAL:

  1. Training Matrix by Job Role
    1. This is provided as part of your company set up. Please keep this for reference and should you need to make adjustments to your training programs, add or remove courses, or job roles we will use this document as a reference. You can also provide this you your accreditation reviewer and licensure inspectors. Contact us if you do not have a training matrix or need an updated
  2. Inservice Training Support Outline, Sign-in Sheets, and Internal Certificate
  3. Use this to document monthly in-service toward meeting your annual hour requirements for face to face training related to ANE and NVCI. Make sure that staff signs the in-service
  4. For new employees when you do this training internally, have them sign the in- service and issue a “in-house”
  5. If you use a live, synchronous training the company who provides this should issue a certificate. Make sure that they record the training and send to you for your licensure
  1. Course Curriculum Description
    1. This document has all of the courses in our catalogue and is the outline, objective and descriptions. These is an explanation of how the hours for each course are determined.