The proposed regulations regarding the education and training of medication aides is convoluted and does not address what happens to aides who already hold a certificate of training approved by the Board of Nursing. Many or these individuals have already received refresher courses in medication administration. The proposed regulations appear to support the training of a medication aide to the training of an LPN without ample opportunity to recieve the training nor compensation comparative with an LPN salary. My experience of 12 years indicate that the problem with errors in medication administration is not in the education or training of staff, but rather in mechanisms in place in the facility to reduce error such as supervision, the ratio of staff to resident per shift, and hourly wages. The present education and training for medication aides is sufficient for the population we serve. The proposed regulations would cause cruel  and undue hardship to aides who presently work in difficult situations with little pay. The reading of the proposed regulations would lead one to believe that effective July 1, 2008 a majority of aides who presently administer medication in Assisted  Living Facilities will be fired and replaced by LPNs.