To better coordinate with licensing who will also be looking at these facilities would you consider:

1)Individualized Service plan instead of Plan of Care 2) recognize that if a resident meets the criteria for a nursing facility and it is noted as such they are not eligible for assisted living - not even a secure unit if licensed under assisted living 3) delete reference to skilled nursing LHCP such as on page 6 4) under 4-c leave the requirement at 19 hours for activities but could remove one-to-one time (this is a new recommendation from RAP looking at standards for secure units) 5) 1630 B-7 is going to require two sets of forms unless the DMAS forms include all info required by Standards (have not seen forms) 6) check references to administrator training with requirements by Long Term Care Board and under new RAP recommendations 7) allow training by personel other than LHCP or clarify that is an option F-2 8) J-standards require a minimum of two people if five or more residents 9) check RAP through DSS for new training recommendations.  This is a welcome opportunity for more elderly persons to be served but if it becomes too heavily laden as a medical model many facilities still will not be able to afford to provide services to these individuals. Thank you to those who were willing to consider changes.