What Happens During a DHS Inspection Related to CPR and First Aid Certifications?

During a DHS inspection in Pennsylvania, Pediatric First Aid and Pediatric CPR certifications are one of the most visible and closely reviewed compliance areas.

Certification representatives from the Pennsylvania Department of Human Services (DHS), under the Office of Child Development and Early Learning (OCDEL), routinely verify that childcare programs meet CPR and First Aid requirements under 55 Pa. Code §§ 3270.31, 3280.31, and 3290.31.

Understanding what inspectors look for — and how those rules apply in daily staffing decisions — helps directors prevent avoidable citations and stay inspection-ready year-round.

The Regulatory Foundation: What DHS Enforces

Pennsylvania regulations require that:

• All staff in licensed childcare programs hold current Pediatric First Aid and Pediatric CPR certification.

• Training must be completed within 90 days of hire.

• Staff may not be left alone with children until training is completed.

• Certification must be renewed on or before expiration.

These requirements apply to:

• Child care centers

• Group child care homes

• Family child care homes

During inspection, DHS representatives verify that these written rules match what is happening in classrooms, staffing schedules, and personnel files.

What Inspectors Review During a CPR/First Aid Compliance Check

1. Staff Certification Documentation

Inspectors typically review:

• Individual staff files containing Pediatric First Aid and Pediatric CPR certificates

• Expiration dates listed on certification cards

• Course titles (ensuring “Pediatric” is clearly stated)

• Instructor or training provider information

They compare names and dates to confirm that anyone counted in ratio or left alone with children holds valid pediatric certification.

2. Hire Dates and the 90-Day Rule

DHS representatives frequently compare:

• Staff hire dates

• Training completion dates

• Current classroom assignments

If a staff member has been employed more than 90 days and has not completed Pediatric First Aid and CPR, this may result in a citation.

If a new hire is left alone with children before certification is completed, that is also a compliance concern.

3. PQAS and OCDEL Curriculum Requirements

For certification to meet Pennsylvania daycare CPR requirements:

• The instructor must be PQAS-approved in Pediatric First Aid and CPR.

• The curriculum must be OCDEL-recognized.

• The training must include a hands-on, instructor-led skills session.

“Online-only” CPR or First Aid courses without a skills component do not meet regulatory requirements.

Inspectors may ask:

• Who provided the training?

• Was there an in-person skills session?

• Is the course pediatric-specific?

Hands-On Skills Requirements: What Matters

OCDEL guidance clearly states that Pediatric First Aid and Pediatric CPR used for compliance must include hands-on skills evaluation.

During inspection, certification representatives may:

• Review certificates for wording that indicates blended or in-person skills testing

• Ask directors how hands-on training was completed

• Confirm that online coursework was followed by an in-person skills session

Programs relying on fully online certification without skills verification risk non-compliance findings.

Expired Certifications: A Common Inspection Finding

One of the most frequent issues during a DHS inspection daycare PA review is expired CPR certification.

There is no regulatory grace period after expiration.

Common findings include:

• Expired Pediatric CPR cards for staff counted in ratio

• Assumptions that renewal can wait until the next scheduled class

• Use of non-PQAS training that does not meet OCDEL rules

If certification has expired — even by a short period — it may trigger a citation under 55 Pa. Code §§ 3270.31, 3280.31, or 3290.31.

Documentation Inspectors Expect to See

Programs that move smoothly through inspections typically maintain:

• A current staff roster listing hire dates and certification expiration dates

• Copies of Pediatric First Aid and Pediatric CPR certificates organized by staff name

• A tracking spreadsheet with alerts 60–90 days before expiration

• Access to PA PD Registry records when PQAS-approved training was used

Organized documentation sets a professional tone and allows inspectors to verify compliance efficiently.

What Commonly Triggers a Citation

Real-world examples of Pediatric First Aid inspection PA findings include:

• A staff member employed more than 90 days without certification

• Expired CPR cards for classroom leads

• Staff without pediatric-specific training left alone with children

• “Online-only” CPR courses used to claim compliance

• Training from a provider not aligned with PQAS and OCDEL standards

Most citations stem from tracking lapses — not intentional non-compliance.

Director’s Pre-Inspection CPR Compliance Checklist

Before inspection, confirm:

• Every staff member has current Pediatric First Aid and Pediatric CPR certification

• Certification includes pediatric designation

• Training was provided by a PQAS-approved instructor

• No staff without current certification are left alone with children

• All certifications were completed within 90 days of hire

• Expiration dates are tracked and renewals are scheduled early

• Documentation is organized and accessible

A 30-minute internal review can prevent unnecessary findings.

Frequently Asked Questions

Is pediatric CPR required for all childcare staff in Pennsylvania?

Yes. All staff in DHS-certified programs must hold current Pediatric First Aid and Pediatric CPR certification.

Does adult CPR meet Pennsylvania daycare CPR requirements?

No. Certification must be pediatric-specific and aligned with OCDEL guidance.

Can CPR be completed fully online?

No. A hands-on, instructor-led skills component is required.

What happens if an inspector finds expired CPR certifications?

DHS may issue a citation for non-compliance, and corrective action may be required.

How do I confirm a course meets PQAS requirements?

Verify the instructor is PQAS-approved and that the curriculum is OCDEL-recognized. Completion may also appear in the PA PD Registry.

A Calm, Proactive Approach to Inspection Readiness

Preparing for a DHS inspection does not need to be stressful.

When directors:

• Track expiration dates

• Verify PQAS approval

• Ensure pediatric-specific certification

• Prevent staffing gaps

They demonstrate leadership, professionalism, and commitment to child safety.

Taking time now to review certifications and documentation helps protect children, support staff, and move through inspection day with confidence.