Act 110 of 2010 Guidance | HAP


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Interim Guidance: Act 110 of 2010



All health care workers in all patient care settings are required to wear a photo identification badge that includes:

  • A recent photograph of the employee
  • The employee’s name
  • The employee’s title
  • The name of the health care facility or employment agency

The title of the employee must be as large as possible in block type and should occupy a one-half inch tall strip as close as practicable to the bottom edge of the badge. Titles that must be spelled out include:

  • Physician for both medical and osteopathic doctors
  • Registered Nurse
  • Licensed Practical Nurse

All other employee’s titles should most accurately describe the employee’s job function and that the public would best understand.

Hospitals must comply with these requirements by June 1, 2015.

Questions & Answers

To which facilities does Act 110 apply?

Act 110 applies to physician offices and entities licensed as health care facilities by the Department of Health including:

  • Ambulatory surgical facilities
  • General hospitals
  • Special hospitals
  • Long-term care nursing facilities
  • Birth centers
  • Home health care agencies
  • Cancer treatment centers

Would the Department of Health grant an exception to a particular requirement within Act 110?

The Department of Health would not have the authority to grant an exception to any requirements in Act 110, as the requirements are part of the statute (law) and only the legislature could change a specific requirement.

The Department of Health has not issued final regulations and it is highly unlikely that it will be able to do so before the June 1 deadline. If the Department of Health, upon the surveying of a hospital, determines the hospital is not complying with the law, it most likely would cite the facility and request a plan of correction.

Do photos have to be less than four years old or updated every four years?

Interim regulations that mandated the update every four years did not apply to the hospital community. The law stated that the interim regulations would expire after 18 months or when final regulations were promulgated, whichever occurred first.

Final regulations were not promulgated, and 18 months have passed from the effective date, therefore, the interim regulations have expired. Currently there is no requirement for photos to be less than four years old or to update them every four years.

The law states that a recent photograph of the employee must be included on the identification badge. The term “recent” is not defined; however, it would be reasonable to consider that the photo would need to be updated if it was so old that it does not even look like the employee (i.e., hair color was red but now it is grey).

Pertinent Links

Download a copy of this interim guidance  

March 2015

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