The most misunderstood line in Connecticut Public Act 26-50 is the January 1, 2027 deadline. Read quickly, it sounds like the date your caregivers must be trained by. It is not. It is the date by which your agency must submit an attestation to the Department of Consumer Protection - and that attestation is a promise, not a diploma.
This article summarizes public sources. It is not legal advice.
What the statute actually says
Section 1(e) of PA 26-50:
"Not later than January 1, 2027, and annually thereafter, each homemaker-companion agency shall submit to the Department of Consumer Protection, in a form and manner prescribed by the commissioner, an attestation in which such homemaker-companion agency agrees to adhere to the training requirements described in this section."
The operative words are "agrees to adhere." Your agency is telling the state it will follow the training requirements. The attestation is forward-looking. It does not certify that any particular caregiver has finished any particular course, and it does not ask you to attach your training records.
Why the distinction matters
The training obligations themselves operate "on and after January 1, 2027" under section 1(a). A caregiver hired in January 2027 has 90 days to complete initial training. So on January 1, 2027, no new employee could yet be past due on initial training. A deadline that required completed training by January 1 would be impossible to meet for anyone hired after early October 2026 - and the statute does not create that impossibility. It creates an agreement deadline instead.
Treating the attestation like a completion certificate cuts both ways badly:
- Agencies that think January 1 is a training-finished deadline may rush or misstate their status.
- Agencies that think the attestation is just paperwork may miss that it is a signed commitment to the state, made annually, in a form the commissioner prescribes.
What your agency must submit, and what it must keep
The attestation and the recordkeeping duty sit in the same subsection but they are different things:
- Submitted to DCP: the attestation, in the form and manner the commissioner prescribes, by January 1, 2027 and annually thereafter.
- Kept by your agency: a list of the training programs your agency uses, including content summaries of those programs, and a paper or electronic copy of every signed completion form for current employees.
The signed completion forms are yours to maintain. DCP published the prescribed initial and annual completion forms on September 30, 2026. The statute's structure is "attest to the state, retain the proof yourself." If the state asks to see your records, your file is what answers.
What "annually thereafter" means in practice
The attestation recurs every year. Each year your agency re-commits to adhering to the training requirements, which include initial training for new hires within 90 days, annual continuing education from the approved list, and the recordkeeping duties. An attestation process that lives in someone's inbox is a process that breaks in year two. The durable approach is a standing record: every caregiver, every signed form, every due date, kept current so the annual attestation reflects reality instead of reconstructing it.
A simple January 1 readiness checklist
- Know where your agency will submit the attestation, in the form and manner DCP prescribes
- Assemble your list of training programs in use, with content summaries
- Confirm every current employee has a signed completion form on file for their completed training
- Set up tracking so new hires' 90-day windows and annual education dates are visible, not remembered
Where Companza fits
Companza keeps the record side of this law in one place: the signed completion forms, the program list and summaries, the due dates, and an exportable agency file when your attestation comes due. Your agency provides the training and signs and submits its own attestation; Companza keeps the paperwork straight so the attestation is a true statement about an organized file. Companza is a records platform, not a training provider, and not a state agency.
Sources
Frequently asked questions
Is the January 1, 2027 deadline when training must be finished?
No. January 1, 2027 is the deadline for the agency's attestation agreeing to adhere to the training requirements. The training obligations themselves operate on and after that date, and new employees have 90 days from hire to complete initial training.
Does the attestation include our training records?
No. The statute requires agencies to retain completion forms and program summaries in their own files. The attestation itself is the agency's agreement to adhere to the requirements, submitted in the form DCP prescribes.
How often is the attestation due?
By January 1, 2027, and annually thereafter.
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