This regulation assumes a "one size fits all" Assisted Living Facility as licensed by the Department of Social Services. In fact, some ALFs are NOT typical in that they:

*do not work with an increasingly older and frailer population

*do not have a high turn over of residents

*do not mirror a nursing home population

For our community (and you note I say community, NOT facility) this new regulation will be cumbersome, unnecessary and costly. We work with a stable group of remarkably healthy adults with mental retardation who come to live most of their adult lives together with us. The care providers are full-time live in VOLUNTEERS, people who choose to make their home here with the residents...In fact we call them co-workers to stress the reality that we are more alike than we are different.

We currently provide the required 32 hour course in medication administration. The changes proposed for the registration of medication aides will impose an undue hardship on our community. For example, in our community the 8 hour insulin module is unnecessary. Not one of our coworkers takes insulin and never has in 35 years. Clearly if someone developed diabetes and needed insulin injections, it would be appropriate to teach those working with that individual. But to propose 8 hours of instruction for every Volunteer on how to administer something that has never been a prescribed medication in the history of our community would be costly and time consuming and inappropriate.

Even some of the more benign aspects of this regulation are inappropriate in our community. One of the regulations requires that Medication Aides who are still in training wear a badge stating that they are a Student-in-Training. The Volunteers who come to our community make this their home and live side-by-side the coworkers in the same household. It would be inappropriate for them to wear a badge in their own homes. Assuredly, every one in the house knows who is living with them, who is new, who has been here for years.

There needs to be room for Variances to this proprosed regulation for situations where it is clearly inappropriate.