1.3 Registry, Renewal, and the 120-Day Rule
Key Takeaways
MBON keeps the nurse aide registry and verifies CNA-I and CNA-II certificates online; facilities use that lookup as proof of status.
Certificates renew every 2 years with a $40 fee and expire on the 28th day of the birth month, in odd years for odd birth years and even years for even birth years.
Renewal needs at least 16 hours of paid work as a nursing assistant in the 2 years before expiration; without them, a CNA-I must pass the competency evaluation again and a CNA-II must complete a training program.
The Board sends a renewal notice at least 3 months before expiry, but not receiving it does not excuse a late renewal; there is a 30-calendar-day grace period after expiration.
The "120-day rule" is the federal 4-month limit: a nursing facility may not use someone as a nurse aide for more than 4 months full-time without completed training and competency evaluation (42 CFR 483.35(d)); candidates get four attempts, at least 45 calendar days apart.
Registry Status Is the Proof
In Maryland, passing the exam is not the final administrative step. MBON keeps the nurse aide registry and certifies CNA-Is and CNA-IIs, and facilities verify status with MBON's online lookup. Federal rules require a nursing facility to get registry verification before letting someone serve as a nurse aide (42 CFR 483.35(d)(4)). A passing notice, a pending renewal, or an employer promise is not the same as a status that can be verified.
The testing vendor (Credentia or Headmaster) posts results; the Board, not the vendor, issues and renews certificates.
Registry and Renewal Rules
| Topic | Maryland rule to know | Why it matters |
|---|---|---|
| Verification | MBON online license/certification lookup | Facilities need primary-source proof |
| Renewal cycle | Every 2 years | Status must be maintained, not earned once |
| Renewal fee | $40 | Budget for renewal even after passing |
| Work requirement | 16 hours of paid nursing-assistant work in the 2 years before expiration | Without it, a CNA-I retests and a CNA-II retrains |
| Expiration date | 28th day of birth month | Not the last day of the month |
| Year pattern | Odd/even expiration year follows odd/even birth year | Lets you predict the cycle |
| Renewal notice | Sent at least 3 months before expiry | Not receiving it is no excuse |
| Grace period | 30 calendar days after expiration | Renew before the date anyway |
| Name or address change | Tell the Board in writing within 60 days | Keeps notices reaching you |
Worked example — expiration date. A CNA-I born in March 1997 (odd year). The certificate expires on March 28 of an odd year (for example, 2027), not March 31, and not in an even year. If a question offers "March 31" or "December 31," both are wrong; the 28th-of-birth-month rule controls.
The 120-Day Rule (Federal 4-Month Limit)
MBON's "120-day rule" is a federal requirement. Under 42 CFR 483.35(d), a nursing facility must not use any individual as a nurse aide for more than 4 months, on a full-time basis, unless that person has completed a State-approved training and competency evaluation program or competency evaluation program. Maryland's CNA regulations refer to the same rule: they exempt someone practicing as a CNA-I for less than 4 months in line with 42 CFR 483.35(d). When stakeholders asked about a waiver, CMS told the Board: "There currently is no existing waiver that would allow a nurse aide to work beyond 4 months after completing the Nurse Aide Training but who has not taken the Competency Evaluation Program (testing)".
Worked example — counting the window. A facility starts using a new full-time aide on June 10. Four months later is October 10. Test early: a canceled test date, or a failed part followed by the required 45-day wait before a retest, can use up the time that remains.
If a Candidate Fails
Maryland allows four attempts in all: the first plus three retakes (COMAR 10.39.01.07). You must wait at least 45 calendar days from the prior evaluation before retaking it, and after a fourth failure you must complete a new approved nursing assistant (or acute care nursing assistant) training program before testing again. You must also sit for the evaluation within 24 months of finishing training, or retake an approved program first. Headmaster's handbook states the four attempts as falling within 24 months of completing training.
Renewal Work Requirements
Renewal requires evidence of 16 hours of active employment, for compensation, as a nursing assistant in the 2 years immediately before the expiration date (COMAR 10.39.01.10). Unpaid care of a family member is not paid work as a nursing assistant. Without the hours, a CNA-I must take and pass the competency evaluation again, and a CNA-II must complete a nursing assistant training program. Keep pay records organized before the renewal notice arrives.
Exam Scenario Pattern
When a question gives an expiration date, choose the 28th of the birth month (matching odd/even year), not the month's end. When a facility uses a new aide who has not finished training and testing, think 4 months full-time. When asked where to verify active status, choose MBON online lookup. When asked about a failed attempt, choose wait at least 45 calendar days, not "retake next week".
Reinstatement of a Lapsed Certification
If you miss the 30-day grace period, the certificate expires, and practicing on an expired certificate is grounds for Board discipline (Health Occupations §8-6A-10). The Board reinstates a certificate when the holder meets the renewal requirements, and someone who has not renewed for 1 year or more must also submit to a new criminal history records check (COMAR 10.39.01.11). The practical lesson is the same: renew before the 28th of your birth month, and keep proof of your paid hours.
Putting the Timeline Together
| Milestone | Trigger | Key number |
|---|---|---|
| Federal 4-month limit | Facility uses an aide not yet trained and tested | 4 months full-time |
| Sit for the evaluation | After training completion | Within 24 months |
| Retest wait | After a failed evaluation | At least 45 calendar days |
| Retraining trigger | Fourth failed evaluation | New approved training program |
| Renewal notice | Before expiration | At least 3 months |
| Renewal grace | After expiration | 30 calendar days |
| Renewal fee and hours | Each 2-year cycle | $40 and 16 paid hours |
Common trap. Candidates assume the 120-day window counts only testing time. The federal rule limits how long a facility can use someone as a nurse aide, 4 months full-time, before training and the competency evaluation are complete. Likewise, do not swap the 16 paid hours for renewal with the 45 days between attempts or the 24 months to sit for the evaluation. Lock each number to its own rule.
A Maryland nursing facility starts using a newly hired full-time nurse aide on June 10, before the aide has passed the competency evaluation. Under the federal rule MBON calls the 120-day rule, what is the limit?
The facility may use the aide for no more than 4 months full-time unless training and the competency evaluation are completed.
The aide may work indefinitely as long as a test date has been scheduled with the vendor.
The limit starts only on the day the aide first logs into the testing vendor's platform.
The facility may apply to CMS for a waiver that extends the limit for slow test dates.
Which renewal statement matches Maryland's rules?
A CNA-I renews every 5 years by earning continuing education credits.
A certificate holder may renew only after the certificate has been expired for more than 30 days.
The certificate expires on the 28th day of the birth month, and renewal needs 16 hours of paid nursing-assistant work in the prior 2 years.
Maryland prints new certification cards after every renewal and no longer uses online verification.
Sections you finish are checked off in the contents.