The Home Care Association of Florida (HCAF) has submitted formal comments to the Agency for Health Care Administration (AHCA) regarding the proposed amendments to Rule 59A-8.0099, Minimum Training Requirements for Home Health Aides for Medically Fragile Children. The rule would establish new standards for the program — commonly referred to as the Family Home Health Aide (FHHA) program — which enables trained family caregivers to provide in-home support for medically fragile children.

HCAF’s comments reflect targeted concerns raised by members about the operational, clinical, and regulatory implications of the proposal, including:

• Clarifying training requirements and ensuring alignment with existing statutory standards.
• Preserving the role of Private Duty Nursing (PDN) and preventing the FHHA program from being used as a substitute for skilled nursing care.
• Establishing clear documentation standards for delegated nursing tasks in electronic medical record systems.
• Removing sterile procedures and tracheostomy care from the list of tasks that may be delegated to aides, as these exceed the legal scope of registered nurse delegation under Florida law.
• Clarifying incident reporting requirements to avoid duplicative or inappropriate reporting responsibilities for agencies.

“These provisions carry significant implications for agency compliance, patient safety, and the integrity of the FHHA program,” wrote Denise Bellville, RN, Executive Director of HCAF. “Our recommendations provide clear, practical solutions to align the rule with state law while ensuring the program functions as intended to supplement, not replace, skilled nursing care.”

HCAF also reiterated its commitment to serving as a resource to AHCA as the rulemaking process moves forward.

Read HCAF’s full comments here.