Florida's Alzheimer's Disease and Related Dementia (ADRD) training requirements are not new, but AHCA's enforcement of them is. Since June 2025, the Agency for Health Care Administration has been issuing citations — logged under survey tag CZ875 (also appearing as ZZ875) — against providers who cannot document that their caregivers completed the required, DOEA-approved training.
If your organization is a nurse registry, home health agency, or homemaker/companion service provider, this citation can apply to you directly, and simply having a training certificate on file is not automatically enough to avoid it.
What CZ875/ZZ875 Actually Means
CZ875 and ZZ875 are AHCA's survey tags for noncompliance with the ADRD training requirements established under Florida Statute 430.5025 (the Alzheimer's Disease and Related Forms of Dementia Education and Training Act, created by House Bill 299). AHCA uses these tags when a survey finds that required training is missing, incomplete, or cannot be verified as meeting DOEA's standards.
This is not a single, one-size-fits-all requirement. The statute defines a broad list of "covered providers" — and different covered providers face different specific training rules, even though a deficiency at any of them can be cited under the same tag family.
Who Is a "Covered Provider" Under F.S. 430.5025?
The statute defines covered provider to include:
Nurse registries
Home health agencies
Companion or homemaker service providers
Nursing homes
Assisted living facilities (ALFs)
Health care services pools
Adult family-care homes
Adult day care centers
This is the point many in-home providers miss: the law does not only apply to facilities. If your registry refers, or your agency employs, anyone who provides "personal care" — which the statute defines broadly to include homemaker or companion services, medication assistance, and other services supporting a client's well-being — you are a covered provider, whether or not that person provides hands-on clinical care.
The Requirement Is Not the Same in Every Setting
This is where a lot of confusion — and a lot of noncompliance — comes from. AHCA/DOEA does not use one training requirement for every covered provider. The hours, timing, and approved curriculum are specific to the care setting:
Nurse registries, home health agencies, companion/homemaker service providers ("in-home" settings): Written info at hire → 1-hour DOEA-approved training within 30 days → 2-hour DOEA-approved training within 7 months
Nursing homes: A separate DOEA-approved 3-hour curriculum specific to the nursing home setting
Assisted living facilities: Also covered under F.S. 430.5025, with its own DOEA-approved curriculum — the exact current hour requirement is genuinely unsettled right now (the governing rule is mid-revision to align with the 2023 statute), so don't rely on any specific number you see online, including this one, without confirming with DOEA directly
Adult day care centers: Their own separate, DOEA-approved curriculum requirement specific to that setting
Each of these curricula is developed, reviewed, and approved by DOEA for that specific setting. That distinction matters more than most providers realize — including for a question we get asked constantly.
Does a 3-Hour (or 4-Hour) ADRD Course Satisfy the In-Home 2-Hour Requirement?
No. This is the single most important takeaway of this whole article, so we'll say it plainly: a longer course built for a different setting does not substitute for the in-home 2-hour requirement — no matter how many hours it runs. This applies whether the other course is the nursing home's 3-hour curriculum, an ALF course (3 or 4 hours, depending on the version), or any other setting-specific training. The reasons are the same regardless of the other course's length:
DOEA approves curricula by setting, not by hour count. A curriculum approved for nursing homes, ALFs, or adult day care centers is approved specifically for that setting. It is a different, separately reviewed curriculum from the one required for the in-home 2-hour requirement — even if it runs longer and covers similar topics. Completing it does not carry the DOEA approval needed to satisfy the in-home requirement.
The in-home requirement isn't structured as a single block of hours. It's two separate, sequenced trainings — 1 hour within 30 days, then a distinct 2-hour training within 7 months, each with its own required content. A single longer session, however thorough, doesn't satisfy a requirement built around two separate completions at two separate milestones.
If your caregivers work in an in-home setting (nurse registry referral, home health agency, or companion/homemaker services), they need training that is specifically DOEA-approved for that setting — not simply an ADRD course that happens to run long enough to "cover" it.
What Actually Makes a Certificate "Accepted" — Trainer and Curriculum
This is the part of Florida's ADRD requirement most providers, and even some AHCA field staff, have gotten wrong — and it is the single most common reason a seemingly-compliant certificate still results in a citation.
DOEA approves two separate things, independently of each other:
A training provider/trainer — the person or organization authorized to deliver ADRD training
A curriculum — the specific course content, approved for a specific setting
Both must be approved, and both approval numbers must appear on the caregiver's certificate. A trainer's name appearing on DOEA's approved list does not, by itself, mean the curriculum they used is also DOEA-approved. The reverse is also true — an approved curriculum delivered by an unapproved trainer does not satisfy the requirement either.
This distinction isn't a technicality we're reading into the statute — it's the exact standard DOEA confirmed directly, in writing, after inconsistent guidance surfaced at a recent Private Care Association conference. At that conference, an attendee asked AHCA representatives whether a widely used ADRD certificate would be accepted, and was told it would — because the trainer was listed on DOEA's website. That answer didn't address whether the curriculum itself was DOEA-approved.
We raised the inconsistency directly with both agencies. DOEA's ADRD Curriculum Specialist, Monica Kosiorek, confirmed the trainer/curriculum distinction and forwarded the clarification internally, writing:
"Thank you for reaching out to us. I have sent internally to all interested parties. I'm surprised by the confusion, but things and people change over time and meaning can get lost in the transition. We appreciate those, like yourself, who want to get it right!"
AHCA's Delray/Miami Field Office Manager, Arlene Mayo-Davis, RN, directed registries to rely on DOEA's guidance on the question, writing simply:
"Please refer to the information from the Dept. of Elder Affairs."
The short version: DOEA sets the training standard. AHCA enforces it. When there's any question about what qualifies, DOEA's guidance controls — and DOEA has now confirmed, in writing, that a certificate needs both an approved trainer and an approved curriculum to satisfy the requirement.
Unfortunately, this gap isn't theoretical. Some widely used ADRD certificate programs list an approved trainer on DOEA's site while their curriculum does not appear on DOEA's approved curriculum list — meaning the certificate can create the impression of DOEA approval without actually carrying it. DOEA has been made aware of at least one such provider and has confirmed it is reaching out directly to address what must change on that provider's certificates. The takeaway for registries and agencies is the same regardless of which provider is involved: don't assume a certificate is compliant because a name looks familiar or a trainer is listed — verify both approval numbers independently, every time.
What Should Appear on a Compliant ADRD Certificate
A certificate that fully documents compliance should include:
The name of the training program
The number of training hours
The trainer's DOEA approval number
The curriculum's DOEA approval number
The curriculum's expiration date (curriculum approvals run three years and must be renewed; trainer approvals do not currently expire)
The trainee's full name and license/certification number (if applicable)
The date and location of training
The trainer's printed name, approval number, and signature
A certificate that only names a course title, or only shows an hour count, does not give a registry, employer, or surveyor enough information to confirm the training actually satisfies the requirement.
How to Verify — Don't Stop at the Trainer
When reviewing a caregiver's certificate, check:
Is there a trainer approval number?
Is there a curriculum approval number?
Was the curriculum active (not expired) on the training date?
Was the trainer approved for the correct care setting?
Was the curriculum approved for the correct care setting and hour requirement?
Can both approvals be independently confirmed on DOEA's public trainer and curriculum listings?
Finding a trainer's name on DOEA's list is the start of that review, not the end of it.
C-E-U.com's DOEA Approval — For Verification
C-E-U.com is an approved ADRD training provider for the home health/in-home setting:
Trainer Approval Number: HH10747
Curriculum: Home Health ADRD Two-Hour Online Curriculum
Curriculum Approval Number: HH10743
Curriculum Approval Date: April 2, 2025
Curriculum Expiration Date: April 2, 2028
Both numbers are printed on every certificate we issue, so registries, agencies, and surveyors can verify compliance without guesswork.
The Bottom Line
CZ875/ZZ875 covers multiple provider types under F.S. 430.5025 — nurse registries, home health agencies, and companion/homemaker providers all fall under the same "in-home" 1-hour/2-hour structure; nursing homes and ALFs have their own, separately approved, setting-specific requirements.
A longer course from a different setting — 3 hours, 4 hours, or otherwise — does not substitute for the in-home requirement, even if the hour count looks comparable or greater.
A certificate is only genuinely compliant when both the trainer and the curriculum carry current DOEA approval for the correct setting — confirmed directly by DOEA and AHCA leadership in writing.
If you administer a nurse registry, home health agency, or companion/homemaker service, review your caregivers' certificates against this checklist now — not after your next survey.