Nursing Services Competency
A complete F-726 §483.35(a)(1) (incorporated through §483.35(c)) competency-and-skills policy plus survey-ready documentation tools for skilled nursing facilities. This template is built to be inserted verbatim into the facility's nursing P&P binder or adapted to site-specific language. It covers the competency framework for nurse aides, the registered-nurse competency framework, the licensed-nurse competency framework, the in-service training and competency-verification cycle, the orientation and pre-employment competency documentation, the annual competency-verification requirement, the competency-tracking log, and the surveyor-encounter workflow CMS uses during F-726 investigations.
F-726 is the F-tag most often paired with F-725 when surveyors investigate both the staffing floor and the competency floor together. The regulation requires that each nurse aide, registered nurse, licensed practical nurse, and other nursing staff member assigned to resident care possess the competencies necessary to perform the resident-care tasks assigned. The competency expectation is not satisfied by licensure alone: the facility must maintain its own competency framework, its own competency-verification records, and its own in-service training cycle that demonstrates each staff member can perform the assigned tasks competently. The most common citation patterns surveyors consistently find are: competency-verification records missing for current staff, in-service training absent for topics tied to recent facility incidents, registered-nurse competency for resident assessment absent, nurse-aide competency for feeding/aspiration absent despite a feeding assistant program, annual competency-verification skipped for members of the nursing team, and absence of competency documentation for staff who perform specialized tasks (restorative nursing, wound care, IV therapy, point-of-care testing).
The role split in this template is intentional. The Staff Development Coordinator (SDC) is responsible for the competency framework, the in-service training cycle, the orientation program integrity, the in-service attendance documentation, the competency-verification cycle, and the training records. The Director of Nursing (DON) is responsible for the clinical competency standards, the competency-verification documentation tied to resident-care outcomes, the supervision oversight for competency gaps, and the survey binder integrity. The unit nurse manager is responsible for shift-level competency verification, the orientation buddy-assignment cycle, and the just-in-time re-verification when a competency gap is identified. The administrator is responsible for the staffing-budget support of the in-service program, the regulatory-release of staff for in-service time, and the policy adoption.
CMS guidance (State Operations Manual Appendix PP, F-726) treats competency as facility-defined but facility-defensible. Surveyors pull the facility's own competency framework, verify that each nursing staff member's assigned resident-care tasks are linked to documented competency, identify any facility-defined competency gap, and trace each gap back to the in-service program or to the corrective action. A license without facility-defined competency verification is treated as a competency-program weakness, not as compliance with §483.35(a)(1). Surveyors also tie competency to F-689 (e.g., fall-prevention competency), F-693 and F-692 (e.g., feeding and nutrition competency), F-714 (e.g., competency for restraint use), and F-758 (e.g., competency for psychotropic medication monitoring and documentation), so the competency framework should integrate with the broader nursing-assessment and intervention workflow.
This template assumes the facility has a current staffing structure, that nursing staff have current and unrestricted licenses in the state of operation, and that the facility maintains the in-service training records required by §483.95(g). If the facility's staffing or in-service framework is incomplete, these are pre-conditions that must be addressed before F-726 is fully operational at the facility.
Purpose
The purpose of this policy is to establish a single, defensible, surveyor-reviewable nursing competency program that meets the requirements of 42 CFR §483.35(a)(1) as manifested through §483.35(c) (nurse aide competency framework), §483.95 (required training), and the corresponding surveyor guidance on F-726. The intent is to convert the facility's competency framework from a license-attestation exercise into a documented, individualized competency-verification system tied to the actual resident-care tasks each nursing staff member is assigned to perform.
Policy
The facility shall maintain a nursing competency framework that documents, for each nurse aide, registered nurse, licensed practical nurse, and other nursing staff member assigned to resident care, the competencies necessary to perform the assigned tasks. The competency framework shall include: orientation competency verification, pre-employment competency verification, annual competency verification, in-service training tied to the assigned task set, just-in-time competency re-verification when a competency gap is identified, and competency documentation that the surveyor can locate for any assigned staff member within the review window. The competency framework shall be reviewed by the DON and the Staff Development Coordinator at minimum annually and any time the facility introduces a new resident-care task category or a new clinical program (wound program, restorative program, IV program, point-of-care testing program). All competency documentation shall be retained for the duration of each staff member's employment plus three years, or per state requirement, whichever is greater.
Scope
This policy applies to all nursing staff (registered nurses, licensed practical nurses, certified nursing assistants, restorative nursing aides, medication aides where permitted by state scope, agency staff at the time of orientation to the facility) who are assigned to resident care in the facility. It applies to the Staff Development Coordinator, the DON, the unit nurse manager, the administrator with respect to staffing-budget support, and the contracted clinical consultant as applicable. The policy applies during orientation, the annual competency cycle, in-service training, just-in-time re-verification, and corrective action when a competency gap is identified. It does not replace state-specific licensure requirements, certification requirements, or scope-of-practice rules.
Procedure
Competency framework
The Staff Development Coordinator shall maintain a competency framework organized by resident-care task category. Task categories include but are not limited to: fall prevention and post-fall assessment, medication administration (oral, topical, eye/ear, inhalation, injection where permitted per scope-of-practice), wound care and dressing change, restorative nursing program implementation, feeding assistance and aspiration precautions, incontinence care, ADL assistance with dignity and safety, transfer and mechanical-lift use, behavior management for residents with cognitive impairment, end-of-life care, infection control and standard precautions, point-of-care testing where performed, IV therapy where performed, tube feeding where performed, and resident assessment using the facility's standardized nursing-assessment tools.
Orientation competency
Every new nursing staff member shall complete an orientation competency verification before being independently assigned to resident care. Orientation competency verification shall include: orientation to the facility's nursing P&P framework, demonstrated competency for each resident-care task category assigned, completion of mandatory in-service modules (resident rights, abuse/neglect prevention, fire and life safety, infection control, and any facility-specific topics), return-demonstration verification for clinically significant tasks (feeding assistance with aspiration precautions, mechanical-lift use, medication administration, wound care where applicable), and sign-off by the orientation buddy and the unit nurse manager.
Pre-employment competency
Each new nursing staff member's licensure status shall be verified prior to start. The verification shall include: an active unrestricted license in the state of operation per the state board of nursing, a review of any disciplinary history relevant to the assigned tasks, in-state and federal exclusion list checks per facility policy, and a reference check on prior resident-care experience. The result shall be documented in the staff member's training file.
Annual competency verification
Each nursing staff member shall complete an annual competency verification that includes the assigned task categories, observed return-demonstration for clinically significant tasks, and a competency assessment documented in the training file. Annual verification shall be completed within the calendar year and shall align with the in-service training cycle. Identified competency gaps shall trigger just-in-time re-verification.
In-service training program
The in-service training program shall be delivered by the Staff Development Coordinator and shall include content tied to: CMS-required topics (resident rights, abuse and neglect prevention, dementia care, infection control, fire and life safety for the entire staff plus nursing-specific modules as applicable), facility-specific topics tied to recent incidents or surveyed gaps, competency-verification tie-in (where in-service attendance is the documented re-verification event for a specific competency), and any new clinical program rolled out facility-wide. Attendance shall be documented and shall be retrievable for the trailing 12 months.
Just-in-time re-verification
When a competency gap is identified through incident review, survey feedback, observation, or care-plan revision, the Staff Development Coordinator shall conduct a just-in-time competency re-verification with the affected staff member. The re-verification shall include: clarification of the gap, supervised re-verification of the specific competency, return-demonstration where applicable, and sign-off by the unit nurse manager. The re-verification record shall be retained in the staff member's training file and shall be retrievable upon surveyor request.
Competency tracking log
The Staff Development Coordinator shall maintain a current competency tracking log for all nursing staff. The log shall include: staff member name, license number and expiration, orientation date, completed in-service modules with dates, annual competency verification date, identified competency gaps and re-verification events. The log shall be reviewed at minimum monthly by the DON. The log shall be the source of the surveyor-encounter documentation set described below.
Documentation
Documentation generated by this program shall include: per-staff-member competency framework (covering assigned task categories and current verification status), orientation competency records, pre-employment license verification records, annual competency verification records, in-service training module documentation with attendance records, in-service session content outlines, just-in-time re-verification records with corrective action where indicated, the competency tracking log, CMS-required training records (§483.95), and the competency-policy itself. Documentation shall identify the staff member completing the entry and the date of completion. Documentation shall be retained for the duration of each staff member's employment plus three years, or per state requirement, whichever is greater.
Staff checklist
Staff Development Coordinator: maintain the competency framework current; deliver in-service training tied to identified gaps; conduct orientation competency verification; ensure annual verification is current for all nursing staff; maintain the competency tracking log. DON: review competency log monthly; approve clinical competency standards; review survey and incident correlation to competency; ensure corrective action when a competency gap is identified. Unit nurse manager: shift-level competency verification for newly oriented staff; sign off orientation buddy assignments; report identified competency gaps to the Staff Development Coordinator same shift; ensure shift-handoff includes competency-relevant updates. Administrator: ensure in-service time is supported with budgeted staffing coverage; ensure the program is resourced to meet CMS-required training frequency; ensure the policy adoption.
Surveyor-encounter sheet
When the surveyor requests F-726 documentation, the facility shall produce, in order: (1) the facility's nursing competency policy; (2) the competency framework by task category for the trailing 12 months; (3) the competency tracking log identifying current competency verification status for all nursing staff; (4) for any specific staff member under review, the orientation record, the pre-employment license verification, the annual competency verification record, and any just-in-time re-verification records; (5) the in-service training module documentation with attendance for the trailing 12 months; (6) CMS-required training records per §483.95 for the trailing 12 months; (7) competency-tied corrective action documentation where any survey or incident has implicated a competency gap. The facility shall produce this documentation set within surveyor timeframes.
Survey prep checklist
30 days before any anticipated survey window, the Staff Development Coordinator and the DON shall complete a pre-survey F-726 audit covering: orientation competency records current for all staff with start date in the trailing 12 months; pre-employment license verification complete for all current nursing staff with hire date in the trailing 24 months; annual competency verification current for all current nursing staff (≥ 95% within calendar year); in-service attendance documentation current for the trailing 12 months; CMS-required training records current per §483.95; competency tracking log current and matches individual staff files; just-in-time re-verification records current where competency gaps have been identified; competency-tied corrective action documentation current where any survey or incident has implicated a competency gap. Identified gaps shall be documented with corrective action and a target completion date, and corrective action documentation shall be retained in the survey binder.
References
Primary regulatory authority: 42 CFR §483.35(a)(1) — Nursing Services (incorporated through §483.35(c) — Nurse Aide Competency Framework); 42 CFR §483.95 — Required Training. CMS State Operations Manual, Appendix PP — Guidance to Surveyors for Long Term Care Facilities, F-726. CMS Long-Term Care Facility Staffing Payroll-Based Journal (PBJ) Policy Manual. State-specific nurse practice acts and state-specific competency framework rules. State nurse aide registry and training program requirements. Facility organizational chart, DON job description, SDC job description, and current nursing staff job descriptions. CMS-required training content per §483.95(g). Cross-references: F-689 (Accidents), F-693/F-692 (Nutrition), F-714 (Restraints), F-715 (Quality of Care general), F-758 (Psychotropic Medications).