Guides · Minnesota

245D staff training: what the statute actually requires.

The 60-day orientation, the topics that cannot wait 60 days, annual training, and the documentation rule that decides whether a licensure review goes well.

The short version: Minn. Stat. 245D.09 requires every 245D license holder to verify staff competency with documented evidence, complete an orientation covering eleven required areas within 60 calendar days of hire, provide person-specific orientation before unsupervised contact with anyone served, repeat the core topics annually, and keep a written plan for how it all happens. Documentation is the practical hinge: a training that cannot be proven reads, to a reviewer, like a training that did not happen.

Who counts as staff — broader than your payroll

Start with the definition — it decides who these rules cover. Direct support staff means employees who have direct contact with persons served — and it explicitly includes temporary staff and subcontractors providing program services under your control, regardless of who employs them (Minn. Stat. 245D.02, subd. 6a). The training duty follows the function, not the W-2. If a staffing agency covers your shifts, those workers need the same training, orientation, supervision, and completed background studies — with documentation you hold (Minn. Stat. 245D.09, subd. 6). Volunteers who provide direct support carry the same obligations (subd. 7).

The competency baseline

The statute's baseline: staff providing direct support, and staff who supervise or manage it, must be competent — demonstrated through training, experience, and education relevant to the primary disability of the person served and that person's needs in the support plan (Minn. Stat. 245D.09, subd. 3). You must verify and keep evidence of that competency, including:

Education and experience documentation relevant to the job — including a valid degree and transcript, or a current license, registration, or certification when one is required.
Demonstrated competency in the required orientation and training areas — through knowledge testing or an observed skill assessment by the trainer, or by someone the trainer previously deemed competent in that area.
Periodic performance evaluations of each direct support staff person, based on direct observation.

Competency is not a signature on an attendance sheet — the statute names knowledge testing or observed skill assessment as the methods. And staff under 18 may not perform overnight duties (Minn. Stat. 245D.09, subd. 3).

Orientation: the 60-day clock and the eleven topics

Within 60 calendar days of hire, unless stated otherwise, you must provide and ensure completion of an orientation that combines supervised on-the-job training with instruction in these areas (Minn. Stat. 245D.09, subd. 4):

The job description and how to perform it — including incident response and reporting, and the agency's safety practices.
Your current policies and procedures — where they live, and staff responsibilities for implementing them.
Data privacy — the Minnesota Government Data Practices Act and HIPAA, and staff responsibilities under both.
Service recipient rights and the staff duties that protect them.
Maltreatment reporting for children and vulnerable adults — required within 72 hours of first providing direct contact services, and annually after that.
Person-centered service planning and delivery, applied to the staff person's own work.
Safe and correct emergency use of manual restraint, and what counts as restraint, time out, seclusion, and chemical restraint.
Prohibited procedures — what they are and why they are neither effective nor safe.
Basic first aid.
Strategies to minimize the risk of sexual violence, including healthy relationships, consent, and bodily autonomy.
Any other topics the case manager requires in the person's support plan, or that you identify.

Practice guidance, not statute: treat 60 days as a ceiling. The 72-hour and before-unsupervised-contact rules front-load most of the real work into week one anyway.

Before unsupervised contact: the person-specific layer

The program orientation is generic. Subdivision 4a adds a layer specific to each person served: before unsupervised direct contact with a person — and again whenever the relevant plans are revised — the staff person must review and receive instruction on (Minn. Stat. 245D.09, subd. 4a):

The person's support plan and support plan addendum as they relate to your responsibilities, plus the individual abuse prevention plan when there is one.
For community residential services, when identified in the support plan: safe techniques for personal hygiene and grooming, healthy diet preparation, and support with daily and instrumental activities of living.
Medication setup, assistance, or administration procedures established for that person — unlicensed staff only after completing a nurse-developed curriculum with an observed skill assessment.
Safe operation of life-sustaining medical equipment such as ventilators or feeding tubes — taught by a licensed health care professional or manufacturer's representative, with an observed skill assessment.
Mental health crisis response, de-escalation, and suicide intervention when supporting a person with a serious mental illness.

One escape valve: in an emergency service initiation, this training must occur within 72 hours of first unsupervised contact, with the reason documented in the person's record. License holders who provide direct support themselves must complete the orientation topics in subdivision 4, clauses (3) to (11) (Minn. Stat. 245D.09, subd. 4a).

Annual training, and what can count toward it

Every year, direct support staff must be trained again on the topics in subdivision 4, clauses (3) to (11) (Minn. Stat. 245D.09, subd. 5). One stated exception: a staff person with a current first aid certification does not need annual first aid training while it remains current. Subdivision 5 was amended during the 2026 legislative session, so check the current text before locking in this year's plan.

Outside training can count. Training on the same subjects from another source counts toward the requirements if received in the 12 months before the staff person's date of hire — provided you keep documentation and verify competency in each area the way subdivision 3 requires (Minn. Stat. 245D.09, subd. 5a).

The paper trail a licensure reviewer pulls

Subdivision 8 requires a written staff orientation and training plan stating when and how you will meet the orientation, person-specific, and annual requirements (Minn. Stat. 245D.09, subd. 8). At a licensure review, expect the reviewer to test that plan against personnel files: hire dates against orientation completion dates, first-shift dates against the 72-hour maltreatment window, assignment records against person-specific orientation, and last year's training against this year's. In most agencies the designated coordinator is who, in practice, ensures staff are trained before working with a person — so the coordinator's monitoring trail gets examined too.

Timing matters right now. DHS stopped accepting new 245D license applications on January 1, 2026, with the pause expected to run through December 31, 2027 — and licensure reviews of existing providers continue through the moratorium. A review backlog was a stated reason for the pause, so expect scrutiny to continue, not relax.

Common questions

How long do I have to complete orientation for a new hire?

The program-requirements orientation must be completed within 60 calendar days of hire, unless the statute states otherwise for a topic (Minn. Stat. 245D.09, subd. 4). Two things move faster: maltreatment reporting orientation must happen within 72 hours of first providing direct contact services, and person-specific orientation must happen before any unsupervised direct contact. The 60-day clock is the outer boundary, not the practical one.

How many hours of annual training does 245D require?

The statute defines annual training by topic, not by a stated hour count in this section: subdivision 5 requires annual training on the topics in subdivision 4, clauses (3) to (11) — from data privacy through sexual violence risk reduction, plus any other topics required in the person's support plan or identified by the license holder. Subdivision 5 was amended in the 2026 session — verify the current text and DHS guidance before finalizing your plan.

Can training a new hire completed at a previous agency count?

Yes, within limits. Training on the same subjects from another source can count toward the orientation and annual training requirements if received in the 12-month period before the staff person's date of hire (Minn. Stat. 245D.09, subd. 5a). You must keep documentation of the outside training and still verify competency in each area the way subdivision 3 requires. No paper, no credit.

Do temporary staff, subcontractors, and volunteers need the same training?

Yes. Subcontractors and temporary staff performing licensed services on your behalf must meet all requirements that apply to those services — training, orientation, and supervision — plus a completed background study, with documentation that the requirements were met (Minn. Stat. 245D.09, subd. 6). Volunteers who provide direct support get the same treatment under subdivision 7.

Who can train unlicensed staff on medications?

Unlicensed staff may perform medication setup or administration only after completing training from a curriculum developed by a registered nurse or appropriate licensed health professional, including an observed skill assessment by the trainer (Minn. Stat. 245D.09, subd. 4a). When the person served has a health care condition that requires specialized or intensive medical or nursing supervision and requires nonmedical service providers to adapt their services to the person's health and safety needs, administration must be taught by a registered nurse, clinical nurse specialist, certified nurse practitioner, physician assistant, or physician.

The vendor part, clearly labeled

Software does not make anyone competent — that takes testing, observation, and a qualified trainer. What software changes is whether you can prove it. Training under 245D.09 is date math against people: a 60-day clock per hire, a 72-hour clock per first shift, a before-unsupervised-contact gate per person served, an annual repeat per staff member, and expiring first aid certifications. In spreadsheets, those clocks drift until a reviewer finds the gap. Tracked where hire dates, shift assignments, and training records live together, expirations surface before they lapse and the evidence a reviewer asks for is a report, not an archaeology project.

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Written and maintained by the ClientCentric team from the working product. Last reviewed 2026-08-31. Source: Minn. Stat. 245D.09 (staffing standards) and 245D.02 (definitions), 2025 Minnesota Statutes. Subdivision 5 of 245D.09 was amended in the 2026 session — verify current text. This is general information, not legal advice.