As a practicing physician heavily involved in the care of individuals residing in a variety of assisted living settings, I would like to voice my strong opposition to the proposed legislative changes. This legislation fails to take into account the broad diversity in assisted living settings that currently exist in Virginia. The legislation is clearly geared toward facilities that care for the oldest, most seriously ill individuals who are on multiple medications, including insulin. I understand the rationale for some of the regulations as they apply to this type of setting, though agree with one of the other respondents that there is no reason an experienced LPN could not oversee the training of medication aides. More important, I have cared for a number of individuals at the Innisfree Village in Crozet, Virginia for over a decade. I cannot call this a "facility" because it is truly a village, a community, serving the needs of mentally handicapped individuals who are generally in excellent physical health. The community is served largely by volunteers who have received appropriate training, in accordance with existing law, and have provided truly outstanding care to my patients. As Ms. Carolyn Ohle has noted in a separate public comment, not ONE "co-worker" (we do not call them residents, as that would belie their superb functional status) has been on insulin in the past 35 years. You could easilty amend the legislation to require insulin training if there is, in fact, an individual ON insulin. Another example: I have an octogenerian under my care at Innisfree, who has been there much of his adult life - he is on NO REGULAR MEDICATIONS. Many of the co-workers are physically healthier than the average Virginia citizen. Finally, it would be a great disservice to make the volunteers in a community such as Innisfree wear name badges - if you were being cared for by your family members at home, would you want your loved ones to be forced to wear name badges? That is effectively what you are asking of the volunteers at Innisfree. This is an intimate community, where coworkers and volunteers know each other intimately. It would only serve to place an "institutional" veneer on what is currently a loving community, where the care of the villagers is nothing short of remarkable.

In summary, it simply does not make sense to make assisted living settings such as Innisfree Village (and I suspect there many others in a similar situation) adhere to such inflexible and "one size fits all" regulations. This legislation MUST be reworded to allow more flexibility and exceptions for the variety of assisted living settings in Virginia. Imposing such restrictions will be sufficiently costly to imperil the financial solvency of such facilities, and I assure you that these negative consequences FAR outweigh the potential benefits in terms of patient safety - if we lose a place like Innisfree, countless individuals will be deprived of the best care and nurturing available in the world. I would strongly recommend that the crafters of this legislation spend a day working and living alongside the co-workers and volunteers of Innisfree Village. Not only will it allow you to revise this overly proscriptive legistlation to reflect the broad diversity of assisted living settings in Virginia, it will give you a glimpse of a model of care that should be disseminated throughout the state, nation, and world.