Phlebotomy training requirements

We are a 500-bed hospital with both inpatient and clinic collection locations. We use a combination of both observed and written tests. The intention of the observation is to ensure that staff are actually doing what they say is being done. We have a simulation lab belonging to the Nursing School that we use to record and observe the whole simulated process, from entry to exiting the room. We (instructor and staff together) use the recording to critique the whole collection process of each staff. While collection is subjective, we do look for specific responses from the phlebotomist that we feel are necessary for courtesy (Press Ganey Patient Satisfaction scores), such as knocking on the door, not turning on the lights until the patient is ready, verbalizing that you're sanitizing your hands before/after collection for their safety, verbalizing that you're labeling their specimens bedside immediately after collection for patient safety, etc. Then the obvious technical requirements, such as order of draw, sanitizing steps of the collection site for regular venous and blood culture collection. We do this for both initial training and annual competency.