2.1 CNA Scope of Practice and Delegation
Key Takeaways
- In California, the CNA role is defined by Health and Safety Code sections 1337-1338.5 and Title 22 of the California Code of Regulations, administered by the CDPH Professional Certification Branch.
- A CNA always works under the supervision of a licensed nurse (RN or LVN) and may only perform tasks within the CNA certificate, the CNA's training, and what the nurse delegates.
- CNAs may not administer most medications, perform sterile procedures, insert catheters or tubes, or make nursing assessments or clinical judgments.
- Delegation does not transfer accountability: the nurse stays responsible for the delegation decision, but the CNA is accountable for performing the delegated task correctly and reporting back.
- Professional boundaries forbid accepting gifts or tips, giving personal contact information, sharing personal problems, or any romantic or financial involvement with residents.
What a CNA Is — and Who Defines the Role
A Certified Nursing Assistant (CNA) in California is an unlicensed assistive person who provides direct personal care to residents and patients under the supervision of a licensed nurse. The role is not self-defined: it is set by Health and Safety Code sections 1337 through 1338.5 and by Title 22 of the California Code of Regulations. The agency that certifies CNAs, investigates complaints, and maintains the registry is the California Department of Public Health (CDPH) Professional Certification Branch.
Because the CNA is unlicensed, the CNA never practices independently. Every task a CNA performs must satisfy three limits at once: it must fall within the CNA certificate (the scope the state allows), within the CNA's education and demonstrated training, and it must be delegated by and performed under the supervision of a licensed nurse. If any of the three is missing, the task is outside scope — even if the CNA feels capable of doing it.
What a CNA May and May Not Do
Most of the CNA day is activities of daily living (ADLs) plus basic data collection. The table below contrasts what is inside scope with what is reserved for licensed staff.
| Within CNA scope | Outside CNA scope (licensed nurse only) |
|---|---|
| Bathing, dressing, grooming, toileting, feeding | Administering most medications (oral, injectable, IV) |
| Measuring and recording vital signs | Inserting urinary catheters or nasogastric/feeding tubes |
| Measuring height, weight, intake and output | Starting or managing IV lines |
| Repositioning, transfers, ambulation, range of motion | Sterile dressing changes and sterile procedures |
| Making beds, basic skin observation | Nursing assessments and clinical judgments |
| Reporting observations to the nurse | Developing or changing the care plan |
In California skilled nursing facilities, medications are given by licensed personnel. A CNA may only assist with a very narrow set of items under direct supervision — for example, a medicated shampoo, a non-prescription lotion applied to intact, healthy skin, or certain over-the-counter items per facility policy. If a resident is choking, bleeding, or deteriorating, the CNA's job is to give basic first aid within training and call the nurse immediately, not to diagnose or treat.
Delegation, Chain of Command, and Accountability
Delegation is the process by which a licensed nurse transfers the performance of a specific task to a CNA while keeping responsibility for the outcome. A safe delegation answers: Is the task within the CNA's scope and training? Is the resident stable and predictable? Will the nurse supervise and be available? CNAs should not accept a delegated task they have not been trained for — they should say so and ask the nurse.
The chain of command is the order in which a CNA seeks direction or raises a concern: the CNA reports to the charge nurse / supervising licensed nurse, who reports to the director of nursing (DON), who answers to administration. Following the chain protects residents and the CNA. If a CNA disagrees with an order or sees unsafe care, the concern moves up the chain — it is never simply ignored.
A key exam point: delegation does not transfer accountability away from anyone — it shares it. The nurse remains accountable for the decision to delegate and for supervision; the CNA is accountable for performing the task safely as trained and reporting the result. A CNA who takes a blood pressure but never reports an abnormal reading has failed an accountability that is squarely the CNA's own.
Working Under Supervision, Boundaries, and Ethics
CNAs always work under a licensed nurse's supervision; during training they work under the immediate supervision of a nurse or instructor, and long-term care facilities must have licensed nursing oversight available on a 24-hour basis. Supervision means a nurse is responsible for the care and reachable for questions — it does not mean the nurse stands beside the CNA for every task.
Professional boundaries keep the relationship therapeutic rather than personal. CNAs must:
- Not accept gifts, money, or tips from residents or families.
- Not share personal phone numbers, social media, or home address.
- Not discuss their own personal problems or burden residents emotionally.
- Avoid any romantic, sexual, or financial relationship with a resident.
- Keep all resident information confidential and protected.
Ethics for a CNA center on honesty, reliability, and respect: report your own errors rather than hiding them, perform care even when it is unpleasant, never falsify a record, and treat every resident with equal dignity regardless of behavior, background, or ability to pay. The CDPH can suspend or revoke a CNA certificate for abuse, neglect, theft, or dishonesty, so boundaries and ethics are not just courtesy — they protect the resident and the certificate.
A frequent exam trap is the "capable but not allowed" scenario. A CNA may have years of experience and feel confident inserting a catheter or pushing an IV medication, but confidence and skill do not extend the legal scope. The correct answer is always to stay within the certificate and call the licensed nurse. Another trap is the "just this once" request from a busy nurse or a demanding family member — performing an out-of-scope task to be helpful is still a violation, and the CNA, not the requester, bears the consequence. **
A licensed nurse asks a CNA to give a resident a scheduled oral blood-pressure medication because the nurse is busy. What is the CNA's correct response?
Which California authority defines and certifies the CNA scope of practice?
When a licensed nurse delegates a task to a CNA, accountability is best described as: