CNA License Renewal: The 24-Month Rule and a 7-State Guide

CNA license renewal keeps a certified nursing assistant active on the state nurse aide registry. Federal rules set the floor: an aide who goes 24 consecutive months without paid nursing work must retrain or retest. Six of the seven states we checked renew every two years, and California and Florida also require in-service training hours.

You have 30 aides, expiry dates on two or three state registries, a few PRN (as-needed) aides who haven't worked in months, and the only reminder is someone remembering. Below are the rules, a 45-minute audit, a copy-paste spreadsheet, a free tracker you can download and a plan for aides who already lapsed.

Key takeaways

• An aide with 24 consecutive months of no paid nursing work must retrain or retest (42 CFR 483.35(d)(6)).
• One documented day of paid work, such as 8 consecutive hours, in 24 months is enough, and it need not be in a nursing home (CMS guidance).
• Certified nursing homes must give each aide at least 12 in-service hours a year, counted from the hire date.
• California requires 48 in-service or continuing education (CE) hours per two-year cycle; Florida requires 24.
• Before a first shift, certified nursing homes must check every state registry likely to hold the aide's record.
• A spreadsheet with =EDATE(last paid work date, 24) flags every aide near the 24-month cut-off; auditing 30 aides takes about 45 minutes.

The 24-month clock starts at the aide's last paid nursing work, not at the date on a card.

What are the federal rules for CNA license renewal?

Federal law sets a work test, not a renewal date: an aide stays eligible as long as they do paid nursing work at least once in every 24-month window.

Under 42 CFR 483.35(d)(6), an aide who goes 24 consecutive months without providing nursing or nursing-related services for pay must complete a new training and competency evaluation program (NATCEP) or a new competency evaluation program (CEP). States must also remove those aides from the registry under 42 CFR 483.156(c)(2).

The Centers for Medicare & Medicaid Services (CMS) tells surveyors in its State Operations Manual, Appendix PP that one documented day of paid work, such as 8 consecutive hours, in the previous 24 months is enough. It need not be in a nursing home, as long as it was paid and included nursing tasks such as help with activities of daily living (ADLs).

What extra duties do certified nursing homes have?

Nursing homes certified for Medicare or Medicaid carry extra duties under 42 CFR 483.35(d) and 42 CFR 483.95(g):

• Verify the registry, in every state likely to hold the aide's record, before they serve as an aide.
• Provide at least 12 in-service hours a year, including dementia management and abuse prevention.
• Count that year from each aide's hire date, not the calendar year (CMS tag F730).

Assisted-living and most home-care employers follow state rules instead, but the 24-month rule still decides whether a CNA stays listed.

How do CNA certification renewal requirements differ by state?

Each state builds on the federal floor, so cycles, work tests and training rules change at the state line. We checked seven large states on their official pages in October 2026.

Official sources for each row, last verified 12 Oct 2026: California CDPH CNA page and renewal requirements; Florida Board of Nursing CNA renewal and s. 464.203, F.S.; Illinois IDPH CNA facts; New York DAL DRS 25-07 and DAL DRS 26-04; North Carolina Nurse Aide I Registry renewal; Pennsylvania Department of Health nurse aide page and Credentia registry rules; Wisconsin DHS registry FAQ.

Check which work settings count. New York says adult care facilities and home care agencies cannot recertify CNAs. Pennsylvania counts paid work in personal care homes. Wisconsin lets aides who worked in assisted living under a registered nurse (RN) or licensed practical nurse (LPN) renew with form F-03211.

Don't count on the state to remind anyone. Pennsylvania's registry contractor sends a notice about 90 days before expiry and Wisconsin's about 60 days. California mails renewal applications 4 months ahead. North Carolina sends no renewal notices at all.

We left out Texas and Georgia because we could not confirm their rules on an official state page in October 2026. For any other state, check your nurse aide registry's official .gov page.

How do you renew a CNA license, step by step?

Start at least 90 days before expiry. These seven steps fit most states.

1. Find the expiry date on the registry. Look the aide up on the state registry and record the expiration date. Don't rely on a card: Wisconsin no longer issues them, Illinois does not issue state certificates, and New York stopped issuing paper certificates on August 1, 2026.
2. Confirm the work test. Check payroll for paid nursing work inside the current 24-month window, and note the last date worked.
3. Count training hours. In California or Florida, confirm the in-service or CE hours are complete before the aide applies. In a nursing home, check the 12-hour yearly minimum separately.
4. Open the renewal window. California accepts applications up to 6 months early. Florida's portal shows the renewal option no later than 90 days before expiry. Wisconsin's system opens 60 days before.
5. Submit the aide's part and the employer's part. North Carolina and Wisconsin need the aide's application plus a verification of paid work from the employer or supervising RN. In New York, the facility files.
6. Pay any fee. Florida charges $55 before expiry and $105 after. In New York, the employer pays the recertification fee.
7. Verify the new date and file proof. Re-check the registry once the renewal posts, save a copy of the listing, and update your tracker. California asks applicants to allow up to 30 business days for processing.

How should employers track CNA certification expiration?

Track every CNA in one sheet with two deadlines, the registry expiry date and the federal 24-month work cut-off, and give each row an owner and reminders at 90, 60, 30 and 7 days.

Do this now: a 45-minute CNA audit

1. Pull the list (5 minutes). Export every active CNA and certified medication aide (CMA), including PRN staff and anyone on leave.
2. Set up the sheet (5 minutes). Copy the layout below into Excel or Google Sheets.
3. Look each aide up on the registry (about 25 minutes). Record the status and expiry date from the registry, not the card, for every state the aide has worked in. Save a screenshot.
4. Add the last paid nursing work date (5 minutes). Take it from payroll, starting with PRN aides, long leaves and rehires.
5. Sort and act (5 minutes). Sort by days left. Message anyone under 90 days today, and move anyone expired to the lapsed plan below.

What should a CNA tracking spreadsheet look like?

Add two color rules to column H. Select column H from cell H2 down and add two conditional formatting rules with custom formulas: =$H2<=30 red, then =$H2<=90 amber, red on top. MIN skips blanks, so Illinois rows use the 24-month cut-off, and a row with no dates shows as overdue.

Worked example (illustrative dates). An aide on leave last worked a paid shift on December 15, 2024. On October 12, 2026, column F shows December 15, 2026 and column H shows 64, so the row turns amber even though their registry date runs into 2027. One qualifying paid shift before then resets the federal clock.

Prefer it ready-made? Our free CNA certification tracker (Excel and Google Sheets, no sign-up) uses the same logic: one row per aide per state registry, the 24-month cut-off, the next deadline, in-service hours still needed, CPR and First Aid dates, color coding, a dashboard and a printable quick-start guide.

What reminder cadence works for CNA renewals?

Each reminder has one job: HR runs the 90, 60 and 30-day checks, and the 7-day reminder escalates to the administrator.

What should the renewal reminder to a CNA say?

Send this at 90 days, by email or text:

"Hi [name], your CNA certification on the [state] registry expires on [date], [number] days from now. Please (1) [state step, e.g. submit the online renewal form], (2) send me your in-service or CE certificates by [date], and (3) reply when you've submitted so I can complete the employer verification. If cost, login or hours are a problem, tell me this week. Thanks, [name, phone]"

In North Carolina, the supervising RN also files an online employment verification. In New York, the facility files and pays, so make it a heads-up.

What should you check before a new CNA's first shift?

Before the aide works a shift (the full caregiver onboarding checklist for assisted living covers the other pre-hire checks):

1. Check every registry. Ask which states they've worked in, then check each registry before the first shift (required in certified nursing homes). Save each result.
2. Confirm recent paid work. After a break, ask for proof of recent paid nursing work, such as a pay stub.
3. Add their row. Start their in-service year on the hire date.
4. Set the first reminder. Do it before the first shift.

What happens if a CNA's certification lapses?

A CNA whose registry status lapses cannot work as a nurse aide in a certified nursing home until they retest or retrain.

It shows up at survey. CMS tells surveyors to check aide personnel files for a registry check before the start date and retraining after any 24-month gap. A missing check can be cited under tag F728.

What should you do if a CNA's certificate already lapsed?

• First, in a certified nursing home: take them off nurse aide duties until the registry shows them active. Elsewhere, check your state's rule first.
• If they did paid nursing work in the last 24 months: renew late. Florida charges $105 instead of $55 and voids the license two years after expiry. In California, the new effective date is the renewal date.
• If they had 24 consecutive months with no paid nursing work: federal rules require a new NATCEP or CEP. In Pennsylvania, the aide gets one attempt at the state exam before retraining. In Illinois, they pass a written competency test.
• If they're in Wisconsin and lost federal eligibility: they can still work as a nurse aide in hospitals, but not in federally certified nursing homes, home health agencies or hospices.
• Whatever the path: file the new listing and any test or training record in their personnel file.

How do you stop CNA renewals from causing staffing gaps?

Start early, check monthly and protect the 24-month clock for aides who rarely work.

• Run a monthly registry check. On the first Monday, re-check every aide due within 90 days. North Carolina sends no notices.
• Protect the clock for PRN staff and aides on leave. Offer a qualifying paid shift before their 24-month cut-off: at least 7 hours in New York, 8 in North Carolina and Wisconsin, or one 8-hour day in Pennsylvania.
• Spread in-service through the year. Schedule hours from each hire date so California aides reach 12 a year instead of cramming 48 at the end.
• Plan cover at 30 days, not 7. California asks for up to 30 business days to process a renewal.

Spreadsheet or software for CNA renewals?

A spreadsheet is enough for fewer than about 10 CNAs in one state when one person checks it every Monday (our estimate, not a rule). The free tracker or the layout above covers that well.

It starts to fail when that person is away, aides hold listings in several states, turnover leaves rows stale, or a surveyor asks who checked what and when. That is where a tool earns its place: ExpiryEdge gives each certificate an owner, a backup and files, sends reminders at 90, 60, 30 and 7 days by email, SMS, Slack or Teams, and logs every check.

For the wider picture, see employee certification tracking, the assisted living compliance guide and our certification expiration tracking checklist.

Frequently asked questions

Is a CNA license the same as a CNA certification?

For renewal purposes, yes. Most states call it a certification or a registry listing, while Florida calls it a license. What matters is that the aide shows as active on the state nurse aide registry.

How often do CNAs need to renew?

California, Florida, New York, North Carolina, Pennsylvania and Wisconsin renew every two years. Illinois has no renewal: an aide keeps CNA status as long as they do paid nursing work at least once in every 24 consecutive months.

How many hours does a CNA need to work to renew?

It depends on the state. California asks for at least one day of direct patient care under licensed supervision, New York 7 paid hours, and North Carolina and Wisconsin 8 paid hours in 24 months. Pennsylvania asks for one documented day of 8 consecutive hours.

Can a CNA renew an expired certification?

Often, but it costs time or money. Florida charges a higher fee after expiry and voids the license two years later. In Pennsylvania and Illinois, an aide with 24 months of no paid nursing work must pass the competency test again.

Does working in assisted living count toward CNA renewal?

It depends on the state. CMS says qualifying work need not be in a nursing home, and Wisconsin and Pennsylvania accept some assisted-living or personal care home work. New York says adult care facilities cannot recertify CNAs.

How do I track CNA expiration dates in Excel or Google Sheets?

Use one row per aide with the registry expiry date and the last paid nursing work date. =EDATE(last work date,24) gives the federal 24-month cut-off, and =MIN(expiry, cut-off)-TODAY() gives days left. Color anything under 30 days red and under 90 amber, and sort by days left weekly.

Sources

• 42 CFR 483.35(d), Requirements for facility hiring and use of nurse aides (eCFR)
• 42 CFR 483.95(g), Required in-service training for nurse aides (eCFR)
• 42 CFR 483.156, Registry of nurse aides (eCFR)
• CMS State Operations Manual, Appendix PP (Rev. 225), tags F728, F730 and F947
• California Department of Public Health: CNA renewal
• California Department of Public Health: How to Complete Your Renewal Application
• California Department of Public Health: Renewal Application Helpful Tips
• Florida Board of Nursing: CNA Renewal
• Illinois Department of Public Health: CNA Facts
• New York State Department of Health: DAL DRS 25-07, Recertification Requirements for Certified Nurse Aides
• Florida Statutes s. 464.203, Certified nursing assistants (2026)
• New York State Department of Health: DAL DRS 26-04, Elimination of Certified Nurse Aide Paper Certificates (July 8, 2026)
• North Carolina DHSR Nurse Aide I Registry: Renewal
• Pennsylvania Department of Health: Nurse Aide Registry
• Pennsylvania Nurse Aide Registry (Credentia): The Registry
• Pennsylvania Nurse Aide Registry (Credentia): FAQ
• Wisconsin DHS: FAQs about the Nurse Aide Registry
• Wisconsin DHS: Providers Verifying Nurse Aide Employment

Last reviewed: 12 October 2026