Nurse Aide Pathway Guide: Seven-State Comparison (Pilot)

About this guide

A high school nurse aide program can graduate students who are ready to sit for their state’s nurse aide exam, but in every state you need a second approval from a health or nursing agency on top of your CTE program approval. This guide shows what that takes in Michigan, Virginia, North Carolina, Arizona, Pennsylvania, Missouri and Hawaii.

The guide is for district and school leaders, CTE directors, ISD and regional center staff, and community partners deciding whether to start or expand a nurse aide (CNA) pathway. Use the federal section for the rules that apply everywhere, then the state table and state notes for what changes where you are.

State rules were checked against agency pages, administrative code and statute in October 2026. Rules and forms change, so confirm the current version with the named agency before you apply.

What high school can deliver and what comes after

In most of these states a student can finish an approved nurse aide training program in high school and leave eligible to test. The training hours fit inside a one- or two-year course sequence, and the credential is earned through a state exam rather than an apprenticeship.

What often waits until after graduation:

• Testing or registry listing. Hawaii lists aides on its registry only at age 18. Arizona’s statute sets 16 to practice, and the Board of Nursing’s rules set no higher age for testing or the registry. The 18 on the Board’s application page applies to medication assistants.
• Hiring. Several state agencies note that many nursing facilities hire aides only at 18, even where training and testing are open to younger students.
• Keeping the credential active. North Carolina requires at least 8 hours of paid nurse aide work every 24 months to stay on the registry. Michigan has required 12 hours of continuing education each year since March 23, 2026.
• The next rung. Nurse aide is an entry credential. Plan articulation into LPN, RN or allied health programs through your state’s dual enrollment mechanism.

Federal rules that apply in every state

Federal law sets a floor that every state program meets or exceeds.

• Training hours. At least 75 clock hours, including at least 16 hours of supervised practical training. At least 16 hours on communication, infection control, safety and emergency procedures, resident independence and residents’ rights must come before any direct resident contact (42 CFR 483.152).
• Instructor. Training is done by or under the general supervision of a registered nurse with at least 2 years of nursing experience, at least 1 of them in long-term care, and instructors need training or experience teaching adults (same rule).
• No federal minimum age. Age limits, where they exist, come from state rules, exam vendors and clinical host sites.
• Patient privacy. Students in clinical placements count as part of the host facility’s HIPAA workforce, paid or not, and facilities may let trainees see patient records under their own minimum-necessary policies (45 CFR 160.103). Expect site-specific privacy training before rotations.
• Bloodborne pathogens. OSHA requires employers to offer hepatitis B vaccination to employees with exposure (29 CFR 1910.1030). Unpaid students may fall outside the federal standard, but host sites will still expect exposure training and protective equipment.
• Patient lifts and paid work under 18. The U.S. Department of Labor treats power-driven patient lifts as hoisting equipment, which 16- and 17-year-olds may not operate on the job. A trained 16- or 17-year-old nurse aide may only assist an adult-led lift team (Field Assistance Bulletin 2011-3). The student-learner exemption does not cover this rule.

State comparison

Every state requires a health or nursing agency to approve your training program separately from your CTE program approval. Age rules range from none (Michigan) to registry listing at 18 (Hawaii).

Your teacher also needs the state’s CTE teaching credential for health science in every state. Training hours appear in the chart below.

Minimum nurse aide training hours run from 75 in Michigan to 175 in Missouri

Clock hours required by state rule. Blue = minimum supervised clinical or practical hours inside the total.

Show the numbers

State	Minimum total hours	Minimum supervised clinical or practical hours
Michigan	75	16
Pennsylvania	80	37.5
Hawaii	100	70
Arizona	120	40
Virginia	140	40
Missouri	175	100
North Carolina	Set per program at approval, above the federal 75
Federal minimum	75

What counts as supervised practice differs by state: Michigan and Arizona count clinical hours, Virginia counts direct client care, Hawaii counts all supervised practical hours and Missouri counts supervised on-the-job training.

Jobs and pay for nurse aides

Most openings come from aides leaving or changing jobs rather than from growth, which is why Pennsylvania has the most openings with the slowest growth. Nationally, nurse assistant jobs are projected to grow 2.3% with about 204,100 openings a year. Sources: BLS Occupational Employment and Wage Statistics (SOC 31-1131) and Projections Central state projections.

State notes

Michigan. Your program needs at least 75 hours: 16 classroom hours before patient contact, at least 16 in-person clinical hours, and 43 more in any mix. LARA processes complete permit applications within 30 days and surveys the site within 60. Students get three attempts at the state exam; after a third failure they must repeat a full program. Since October 2, 2026, students get work permits through LEO’s online Youth Employment Permit Portal, and employers register there before hiring minors. During the school year, 16- and 17-year-olds may work no more than 24 hours a week. Michigan’s long-term care background check law names employees, contractors and people with clinical privileges, not students; your clinical site may still require a check by policy. Ask how it handles students under 18. (Confirm with the agency)

Virginia. Your program must run at least 140 clock hours, with at least 24 hours of instruction before client contact, 20 skills-lab hours and 40 hours of direct client care. Simulation does not count toward the 40 hours. Clinical and lab groups are capped at 10 students per instructor. Students must test within 24 months of finishing. State law bars anyone under 16 from paid nurse aide work in hospitals and nursing homes.

North Carolina. No statewide hour total is set in rule. DHSR sets your hours when it approves the program and will not approve a program at the bare 75-hour minimum. The HN43 course runs 270 to 300 hours, so most school programs clear any likely total. Clinical groups are capped at 10 students per teacher. Staying on the registry takes 8 hours of paid aide work every 24 months.

Arizona. Your program must run at least 120 hours: 40 classroom, 20 lab, 40 clinical and 20 more distributed by the program. At least 20 clinical hours must be direct resident care in a long-term care facility. You may not advertise, recruit or collect fees before Board approval. Arizona requires no work permits, and its child labor law exempts students in state career and technical programs. Graduates can be listed as Certified Nursing Assistants, or apply for the Licensed Nursing Assistant credential, which adds fingerprinting and fees.

Pennsylvania. Plan for at least 80 training hours with at least 37.5 hours of supervised clinical experience. PDE, not the Department of Health, approves nurse aide training programs. Students need a Pennsylvania State Police criminal history report before they enroll and must test within two years of finishing.

Missouri. Plan for at least 175 hours: 75 hours of instruction and 100 hours of supervised on-the-job training. Students take the state exam through Headmaster D&S and need 80 percent on the written test and 100 percent on the skills check.

Hawaii. Your program must run at least 100 hours: 30 classroom hours, 16 of them before resident contact, and 70 hours of supervised practice split among an RN, an LPN and a licensed therapist. Med-QUEST’s July 11, 2025 list of certified programs shows no HIDOE school-run program. Farrington, Kauai and Mililani high schools operate as satellite sites of Leeward Community College’s certified program, so plan on a partnership with a certified provider and confirm the current list. (Confirmed as of July 2025; Confirm with the agency) Students can train before 18 but are listed on the registry at 18.

Launch steps

Each step below has a companion toolkit with the detail, templates and options. This table gives only what is specific to nurse aide programs.

Protecting college options

A nurse aide pathway should add to a student’s options, not narrow them. Schedule the nurse aide courses alongside a full college-preparatory core rather than in place of it. If you want health science coursework to count toward an academic credit, treat it as a separate local decision, check your state’s credit rules, and confirm the result with the admissions offices your students apply to most.

Sources and open questions

Confirm with the agency

• Arizona: whether the exam vendor sets its own age minimum for 16- and 17-year-old completers. Statute sets 16, and the Board’s rules set no higher age.
• North Carolina: which age guidance governs school programs, DHSR’s 16 and a half at enrollment or the DPI course page’s 16 on the first day.
• Hawaii: whether any public high school now holds its own Med-QUEST program certification, and whether Prometric still runs the exam.
• Pennsylvania: the rule citation for the 80-hour and 37.5-hour clinical minimums (confirmed through the state exam vendor and PDE’s schedule, not yet in rule text).
• Virginia: whether 18VAC90-26 has been amended since 2021, and current course codes for condensed nurse aide formats.

Changing

• Michigan added a 12-hour annual continuing education requirement for registry renewal on March 23, 2026; watch for LARA implementation guidance.
• Exam vendors and state credential lists change; confirm the current vendor and approved credential list each year.
• Arizona’s regional in-demand program list is updated each year.

Last checked October 2, 2026.

Federal sources: 42 CFR 483.152 · 45 CFR 160.103 · 29 CFR 1910.1030 · DOL Field Assistance Bulletin 2011-3

State sources:

• Michigan: LARA nurse aide rules R 400.301 to 400.357 · LARA Nurse Aide Registry · MDE Cluster and CIP list · LEO youth employment permit portal
• Virginia: 18VAC90-26 · Credentia exam eligibility · CTE Resource Center, Nurse Aide · 8VAC20-23-250
• North Carolina: DHSR program coordinator orientation · DHSR student age guidance · Nurse Aide I education requirements · HN43 course page · DPI CTE Licensure Manual
• Arizona: R4-19-802 · R4-19-804 · A.R.S. 32-1645 · AZBN license application · ADE Nursing Services
• Pennsylvania: PDE nurse aide training program · PDE instructor guidelines · Credentia PA FAQ
• Missouri: 19 CSR 30-84.010 · DHSS trainer page
• Hawaii: HAR 17-1444 · HAR 16-89A · Med-QUEST certified program list, July 11, 2025