245D training requirements: orientation and annual topics (245D.09)

245D training requirements are set by Minn. Stat. § 245D.09, the staffing standards section of Minnesota's home and community-based services (HCBS) licensing chapter. Direct support staff must complete orientation to program requirements within 60 calendar days of hire, be trained on maltreatment reporting within 72 hours of first direct contact, be oriented to each person's support plan before working with that person unsupervised, and complete annual training on the listed topics.

The most common misunderstanding is about hours. Older guides, and the 2013 version of the statute, describe 30 hours of orientation and 24 hours of annual training. As of September 2026, § 245D.09 sets a competency standard instead: orientation "sufficient to create staff competency" that combines supervised on-the-job training with instruction, with competency shown by testing or observed skill assessment. The Department of Human Services (DHS) licensor checks topics, dates, and competency evidence, not a total.

This guide covers who the rules apply to, staff qualifications, the 60-day orientation topics, person-specific orientation, the history of the hour counts, annual training, background studies, the training record a licensor asks for, and how to track expirations. For the license itself, see the 245D license guide.

Who the 245D training rules apply to

§ 245D.09 applies to direct support staff, defined in § 245D.02, subd. 6a as employees who have direct contact with persons served, including temporary staff and subcontractors providing program services. It also reaches staff who supervise or evaluate direct support staff, since subd. 3 requires those supervisors to be competent too.

• Subcontractors and temporary staff. Subd. 6 makes the license holder responsible for ensuring that any subcontractor or temporary staff person meets and maintains every requirement of the chapter for the service provided, including training, orientation, supervision, and background studies under §§ 245C.03 and 245C.04.
• Volunteers. Subd. 7 requires the training, orientation, and supervision necessary for their responsibilities and a completed background study.
• Designated coordinator and designated manager. § 245D.081 sets their qualifications: a degree, diploma, or at least 50 hours of related education paired with one to four years of full-time direct care experience for a coordinator, plus at least three years of supervisory experience for a manager.

Staff qualifications and competency under subd. 3

§ 245D.09, subd. 3 is the standard the rest of the section serves. The license holder must ensure that direct support staff and their supervisors are competent through skills and knowledge training, experience, and education relevant to the primary disability of the person and to the needs in the support plan. The license holder must verify and keep evidence of three things:

1. Education and experience relevant to the job and the disabilities served, including a valid degree and transcript or a current license, registration, or certification where the chapter or the support plan requires one.
2. Demonstrated competency in the orientation and training areas, determined "through knowledge testing or observed skill assessment conducted by the trainer or instructor" or by someone the trainer has already deemed competent in that area.
3. Periodic performance evaluations of the staff person's ability to do the job, based on direct observation (except for a license holder who is the sole direct support staff).

Paragraph (b) adds one hard rule: staff under 18 may not perform overnight duties.

Orientation to program requirements: the 60-day window

Under subd. 4, within 60 calendar days of hire the license holder must provide and ensure completion of orientation that combines supervised on-the-job training with review of and instruction in the following areas, as they relate to the staff person's job.

Agencies that already run HIPAA workforce training can count it toward clause (3) if the record shows the date and content; the HIPAA compliance guide for Minnesota home care agencies covers what that training should include.

Audit tip: the 72-hour maltreatment deadline is the one most often missed, because it falls inside the first week while the rest of orientation is scheduled across two months. Put it on day one and record the trainer.

Orientation to the person: subd. 4a

Program orientation is not enough to work alone with a client. Subd. 4a requires that before having unsupervised direct contact with a person, or with a person the staff member has not supported before, or whenever the relevant plans are revised, the staff person reviews and receives instruction on:

• The person's support plan or support plan addendum as it relates to the license holder's responsibilities, and when applicable the individual abuse prevention plan, so the staff person understands the person as an individual and how to implement the plans.
• For community residential services, if identified in the support plan: safe techniques for personal hygiene and other activities of daily living, what a healthy diet is and how to prepare it, and support for instrumental activities of daily living.
• The care procedures in the plan such as medication administration, medical equipment, and crisis response, where they apply to the person.

In an emergency service initiation, the training must occur within 72 hours of the staff person's first unsupervised contact. The 245D documentation checklist explains the plans this orientation is built on.

Was there a 30-hour rule? The history of training hours

Yes, and it matters because many policies still quote it. The 2013 version of § 245D.09 required the license holder to "provide and ensure completion of 30 hours of orientation" within 60 days of hire, and required "a minimum of 24 hours of annual training to direct service staff with fewer than five years of documented experience and 12 hours of annual training to direct service staff with five or more years."

The legislature later replaced those counts with the competency language now in subd. 4 and subd. 5, and added subd. 5a, "Alternative sources of training." As of September 2026 the current text contains no hour requirement. A policy that promises 30 hours is not wrong, but it becomes a self-imposed standard the licensor can hold you to.

Annual training under subd. 5

Subd. 5 requires annual training for direct support staff on the topics in subd. 4, clauses (3) to (11): data privacy, service recipient rights, maltreatment reporting, person-centered planning, emergency use of manual restraint, prohibited procedures, first aid, sexual violence risk, and any other topics the license holder requires.

One substitution is written into the statute: if the staff person holds a current first aid certification, the annual first aid topic under clause (9) is not required as long as the certification remains current. That makes the certification expiration date a compliance date in its own right.

Background studies and Minnesota Revalidate

Training and background studies are checked together. Under chapter 245C, every direct support staff person, subcontractor, temporary worker, and volunteer with direct contact needs a background study submitted through NETStudy 2.0, and § 245C.04 requires the study to be submitted before the individual begins in a position allowing direct contact. The personnel record must document it (§ 245D.095, subd. 5).

Minnesota Revalidate 2026, launched January 26, 2026, adds fingerprint-based background studies for direct and indirect owners of providers of high-risk services. The Minnesota Revalidate guide tracks those dates.

The training record DHS licensors ask for

§ 245D.095, subd. 5 is the checklist for the personnel file. For each staff person it must document:

• Date of hire and the employment application.
• Acknowledgment of job duties and verification that the person met the position requirements.
• Documentation of qualifications: degrees, transcripts, licenses, or certifications required by the chapter or a support plan.
• Dates of training completion, the number of hours, and the name of the trainer for each orientation and annual topic.
• Competency evidence under § 245D.09, subd. 3: the test score or the observed skill assessment, and who conducted it.
• Periodic performance evaluations based on direct observation.
• Background study documentation under chapter 245C.
• For staff hired after January 1, 2014, the dates of first supervised and first unsupervised direct contact with persons served.

Subd. 8 of § 245D.09 is titled "Staff orientation and training plan," and licensors expect to see the written plan that produced the records above. When incident or restraint reviews under § 245D.061, subd. 6 find a need for additional staff training, the training delivered in response should also appear in the file; the 245D incident reporting guide covers that review.

How to track expirations

A 245D agency with a few dozen staff is carrying several hundred dates. The ones that generate findings are:

Track them per staff person and per client, because the 4a dates attach to the pair. Set alerts ahead of the date, and record the trainer and hours when training happens rather than at review time.

How Trustora helps

Trustora keeps the § 245D.095, subd. 5 personnel record for each staff person: hire date, qualifications, background study status from NETStudy 2.0, each orientation and annual topic with its completion date, hours, and trainer, competency evidence, and performance evaluations. The compliance engine tracks the 72-hour, 60-day, and annual dates and the per-client subd. 4a orientation, and it blocks a shift from being scheduled with a client the staff person has not been oriented to.

Gap-day alerts fire before a training or certification lapses, and the one-click DHS audit binder produces the training record for any staff sample and date range a licensor requests. Role-based, field-level access keeps personnel data separate from client data. See the platform overview for scheduling and staff compliance together.