I am writing to offer an Operator's perspective on what the effects of the proposed Med Aide regulations will be.  As President of Commonwealth Assisted Living, I oversee the operation of five Assisted Living facilities with approximately 300 beds.  We have over 200 employees, a majority of which are nurse’s aides, CNAs, and Medication Technicians.

As I am sure you are aware, our biggest problem in the long term care industry is the availability of labor.  There are simply not enough trained individuals for all of the positions that are available.  Three major forces drive the shortage of Med Techs:

1.      There are not enough classes available.  While our pharmacy offers monthly classes, they are often booked up months in advance.  Technical schools offer the class, but typically only once a semester.

2.      The cost of the classes deters staff from taking them.  Again, our pharmacy offers an inexpensive training, but we have trouble getting our staff in these classes.  Currently, technical schools are charging around $400 for tuition. 

3.      Aides cannot afford to miss the current 32 hours of work without pay.  Due to the high turnover in the industry, facilities are reluctant to pay employees for their time off, and due to staffing shortages, they generally end up paying overtime in order to provide the employee with the time off for training.

While well intentioned, we do not feel that the proposed regulations are going to achieve the desired results, and further, they will have a negative impact on the industry.  First, they will shrink an already undersized labor pool.  It appears that nothing has been done to address the availability of classes.  An increase in required training hours will serve to increase tuition that already has affordability issues, an increase in the economic cost to the student (who must miss work to attend the class), and increase of economic costs to the facility in the form of overtime while the staff is training, as well as increased labor costs inherent of a further shrunken labor pool.

The most frequent medication errors in our facilities fall into two categories:

1.      Med Techs do not follow up to document the effects of a PRN medication one hour after it is given.

2.      Holes in the MAR, where a medication is given but not documented on the MAR.

It is our opinion that our top medication errors are not education related, but rather they are related to management and oversight, and are a result of an inherently flawed documentation system.  In one instance, we replaced all of the Medication Technicians in one facility with LPNs, who receive more training than that proposed in the new regulations.  The result was disappointing in that med errors did not go down, and the nurses did not participate in the care of the resident.  The forms are simply hard to read and document, and they are subject to human error.

We support solutions that will make a real difference in the quality of care our residents receive.  We support:

1.      A state registry for Medication Technicians similar that currently in existence for CNAs.  This will improve accountability and serve to keep unqualified aides out of the position.

2.      Leaving the curriculum at 32 hours and requiring state licensing agencies to ensure that the class is available monthly at a low cost basis.  This will serve to improve two major problems, accessibility and affordability.

3.      A requirement for all Aides to take the refresher course on an annual basis, bringing them up to date on any technical changes to the industry.

4.      The mandatory computerization of the Medication Administration Record.  This technological change is long overdue and would virtually eliminate our two most prevalent medication errors.  The technology is available, and if it were used on a widespread basis, would come down to a price that is affordable. 

We support the idea of improving the care our residents receive.  However, we do not feel that the proposed regulations are going to have a positive impact on our residents or our industry.  The effect of more hours will reduce our labor pool, drive up wages, and not have a positive effect on resident care.  From an operator standpoint, we would rather invest in the solutions above, which we feel would work and would improve the services we offer. 

I look forward to working with all interested parties in the future to improve the quality of care in the Assisted Living industry.