1.  22VAC 40-72-200. The subsection of this standard, 200 B., refers to a "...qualified acting administrator who is not required to be licensed shall be appointed...". The standard does not describe the qualifications of the unlicensed acting administrator.

2. 22VAC 40-72-910 B,C. The change in term from "facilities" to "buildings" could be interpreted that there will be a license issued to each building individually rather than one to the overall facility. Perhaps it could be reworded to read " buildings with a licensed CAPACITY  of...". This would be inclusive of faciity buildings with capacity limitations or stipulations.