Thank you for the opportunity to review and comment on the repealing and replacing of the General Procedures and Information for Licensure. Unfortunately, without sufficient information of the proposed changes, it is difficult to give comprehensive review and response at the NOIRA stage regarding the proposed changes to the general procedures. On behalf of the Virginia Assisted Living Association, we strongly disagree with the process of a wholesale repeal of existing language to be replaced by the new langue. To ensure a thorough review of final set of regulations, we request that a version of the new regulations with the changes tracked be made public so that stakeholders can easily review and provide quality feedback on the new language. If tracked changes is too cumbersome for the Department staff, then we strongly request the Agency provide a means to compare the new language with the existing language. Trying to determine where the changes have been made without an underlined/strike-through version will prove to be very cumbersome to all other parties involved, including the providers, the general public, the State Board Members, and other regulatory agencies. These regulations go the heart of operations for Assisted Living communities, and it is far too important to risk having even the smallest of changes overlooked that could result in the loss or denial of licensure. Given the limited time and attention that the State Board Members, the Secretary’s office, and the Governor will have to give to the review of this major overhaul, we think that the more information available to all interested parties, including the public, will only help to ensure the best possible product and outcome.