A state exam would be more relavent to our standards.We are regulated by the state .Everyone who has passes the National exam should be grandfathered in . Would this delay the deadline of Jan.09? I have heard some operator's have chosen to simply walk away from all the new regulations and close their facilities,those close to retirement.All the new regulations are clearly unfunded,which pushes more operators out,especially a.g.homes.This is happening at the worst time ,right when we are needed the most .All should be put on hold until the a.g.rate has increased to a proper level .Minimum wage increase alone increases payroll by 50-75 cents per hour ,while a.g.usual increase is 50 cents a day.Everyone agree's the rate is to low.

I have been selling insurance to assisted living facilities in Virginia since 1995 and our agency currently insures over 60 facilities Virginia. The amount of regulation on this industry is managable but does pose significant problems for operators to deliver an affordable product to the seniors they serve.   One major point to this is the requirements mandated by new regulation concerning Assisted Living Administrators.  Many of my customers have recently complained about how difficult and expensive it is to hire qualified Administrators.   By using the National Administrator Exam, instead of a State Specific Exam, we make the already arduous task of hiring an administrator even more difficult.  I am in favor of a state exam and to the best of my knowledge I do not have a single Assisted Living Client who disagrees with my opinion.  In order to better serve the Seniors and others in our state who occupy an assisted living bed, please pass legislation for Virginia to offer a state specific exam.

Thank you,

John Marco Warner  Principal and Manager of  Trustpoint Insurance, Richlands, Virginia

While I support the idea of a state exam, having already studied, passed, and paid for the national exam as required by the existing rule and regulations, I would only support the state exam, if those, who have completed and passed the national exam were exempt from paying an additional fee and sitting for another exam.   By changing the law at this point, those who have already complied with the current and existing regulation would suffer an undo hardship. 

I support State examination for licensing of adminstrators. Competence and effectiveness in understanding and meeting the regulations of an Assisted Living Facility in the Commonwealth of Virginia can be met by the following:

• Current hiring requirements of an administrator
• AIT program (Administrator-In-Training)
• State examination of the Standards for Assisted Living Facilities
• Continous review of the standards by the Administrator

I have been an Administrator of 2 small group homes with 14 beds for 9.5 years. The cost of taking the prepratory class, as well as the cost of a national examination, is a financial burden for my budget. Small group home administrators make up approximately 25% of the Assisted Living Facilities in the Commonwealth of Virginia. This cost would be burdensom for the small group home budget.

I am also concerned about the lack of administrators to operate facilities in the future under such stringent qualifications and testing, particularly in the face of the emerging baby boomer healthcare crisis,

Please consider a State Examination as an alternative to the Federal Examination. In order to effectively operate an Assisted Living Facility in the Commonwealth of Virginia, I need information on Virginia regulations not national regulations.

Thank you for considering my thoughts,

Linda J. McCorkindale, RN, BSN, CCM

Administrator, Potomac Homes Assisted Living

I support a state exam vs a national exam. Assisted Livings are licensed by the state and after going through a refresher course, realized that the standards by DSS are not going to be on the exam.  These standards have been drilled into our heads and they are not even on the exam? ! ! The instructor told us to basically forget everything we have been taught in the past and a lot of the information we went over, was new to me.

The cost of this exam is outrangeous. Not everyone can afford it or have a corporate office to help with the cost. There is already a shortage of Assisted Living Administrators in Virginia and having a national exam, will only worsen the shortage problem. Furthermore, the AIT program, there is only a few people who are able to be a mentor for an AIT program- most of them out of the AL's locality.

Please consider a state examination vs a national exam.

Thank you

Misti Binford, Executive Director

Greenfield Assisted Living of Petersburg

The fee is so large that the average person cannot afford to pay it to take the test.  These individuals are crucial to our industry that we can't let them slip away due to this problem.

Let's let the State of VA test for the individuals we so greatly need to work in our caregiving facilities!

Regards-

Sharon Rose, Adm.

As an assisted living administrator for 12 years I feel that the National Exam is extreme.  We started with very simple requirements to be an administrator and then overcorrect with a National exam.  I feel that there are many smaller homes that can not afford a national exam and there are many administrators who may not be able to pass the exam.  Why not start with a state exam since we are regulated by our state?  If we are required to take a national exam why arent' the other states required to be LALA?  The State Regulations are our guide to run our facilities and the test does not revolve around that.  I feel that it would be better to start with a state test and move forward from there.

·         The assisted living industry is regulated by the Commonwealth of Virginia, not by federal standards.

·         In a letter sent to Marilyn Tavenner, the Secretary of Health and Human Resources, on May 8, 2007, Governor Kaine supported the use of a state exam and wrote the following: “…I’d like to make sure that regulations for assisted living administrators strike an appropriate balance between ensuring quality administrators and allowing an adequate pool of such administrators from which to draw. Accordingly, I ask that you confer with the Department of Health Professions on these regulations to revisit three points. First, I’d like you to revisit the need for a national exam in additional to a state exam. …”

·         There is already a labor shortage of assisted living administrators due to several factors, which include:

o   Flee of qualified persons to neighboring jurisdictions

o   Lack of desire from persons in other states to come to Virginia due to stringent requirements to become licensed

·         Only two other states require the national examination to license assisted living administrators. A third state required the examination until recently when they changed their regulations to require a state examination.

·         The cost of the national exam and study guide is approximately $400, which is cost prohibitive for many individuals who must pay the costs out of their personal pockets. This financial restriction will result in the loss of compassionate and outstanding administrators who can not afford the costs.

·         The assisted living industry does not support a national examination.

I have been the ED at this facility since 99. I hold a valid LPN license from the BON.  The cold hard fact is that haviing another license will not keep our building full, provide any better care than we do now or find us any more staff. The established reputatation and relationship with DSS licensing is what I base our success on. If I'm required to take a National Exam I have no idea how it will benefit my building. 

I support replacing the national examination required for assisted living administraors with an examination based on Virginia's regulartions for the following reasons:

• What is most pertinent to an administrator of assisted living in Virginia are the regulations for the Commonwealth of Virginia, not federal standards;
• Virginia already faces a shortage of administrators for assisted living and making the licensure requirements more rigorous will discourage persons from other states from coming to Virginia for this line of work, as well as cause some of those currently working in Virginia to go to other states;
• Out of 50 states, only two others require the federal examination.  A third state that did use the federal standards has since rescinded that requirment in favor of state examination.
• The cost of the national examination and study guide are prohibitively expensive, and many outstanding and experienced administrators may not be able to afford to take the exam.
• Both the assisted living industry, nor Governor Tim Kaine support the use of the state examination.

Thank you for consideration of these comments.

Cheryl Cooper

Some comments I have:

ALF's are regulated by the Commonwealth of Virginia, not by federal standards.

Per  Governor Kaine's comments: Please revisit the need for a national exam in addition to the

state exam.

There is already a labor shortage of ALF administrators due to several factors, which include:

      Flee of qualified persons to neighboring jurisdictions

       Lack of desire from persons in other states to come to Virginia due to stringent requirements

          to become licensed

Only two other states require the national examination to license assisted living administrators.

The cost of the national exam and study guide is approximately $400.00, which is cost prohibitive

for many individuals who must pay the costs out of their personal pockets.  This financial restriction

will result in the loss of compassionalte and outstanding administrators who can not afford the costs.

The assisted living industry does not support a national examination.

Thank you,

Debbie Crisman                                                                                                                   KJ

It is really sad when Assisted Living Administrators must fight for their jobs through being tested so much to prove they can do what they may have been doing for years.  I have been an administrator since 2000 in the same facility.  My residents are taken care of very well and most of the care was not learned from a test.  It is a natural, good and common sense approach to the care of others.  The costs associated with all of the proposed licensing is ridiculous and will continue to push good administrators out of their jobs as they may not have a corporate office to help offset the expense. 

What happened to the "grandfathering" of people who do their job very well and how about discontinuing the constant "not knowing what the state will come up with next" to try pushing us out of our jobs.  Continuing education is fine and we all do that but enough is enough with fees that hit us right and left.  As administrators, we have enough to do trying to abide by the rules and regulations that govern us.  Give us a break.

I, Helga S. Mills, am in support of a state vs. a national exam

I am the owner of a  small 5 bed private pay facility and having to put out large sums of money for a national exam will add an extrem hardship on my budget

I am in favor of a state exam

Helga S. Mills

Mtn. Valley Elder Care, Inc.

Axton VA 24054

Administrators in VA are regulated by the Commonwealth of VA not the federal government.  Testing on a national level will not ensure quality administrators for this state.

Quality administrators, whether it is because of expense or fear of testing, will leave VA and go to neighboring jurisdictions.  Also, there will be a lack of quality people coming to VA to practice due to stringent licensing requirements.

Only two states require a national exam.  A third tried a national exam and changed to a state exam.

TI think that the Assisted Living Administrator Exam should be a State Exam, not a National Exam, because we operate on State Regulation, not National Regulations.    We are more familiar with the State Regulations under which we operate  every day.  I too am concerned that many administrators are going to be lost because of this exam and as a result many residents of assisted living facilities may be endanger of losing their homes, because many will be forced to close.

Working with Seniors in the state of Virginia it would be more appropriate for  administrators to take a state test. We are familiar with the regulations in the state and what is required for licensing.We use and deal with state info every day.It makes more sense to practice the procedures and be licensed by our home state, instead of preparing for a national exam which doesn't pertain to alot of our regulations.This will enable administrators to care for our residents and give them a higher quality of care and better quality of life.Thank you for taking my comment.

As both a Licensed Assisted Living Administrator and a Licensed Nursing Home Administrator in the Commonwealth of Virginia, I strongly oppose the proposal to replace the current national examination for Assisted Living Administrators with a state examination based on Virginia’s regulations.

Quality of care in assisted living should be of utmost importance to all of us in the field. The Administrator is the key leader in establishing and maintaining quality and safety in an assisted living facility.

In 2006, the Department of Social Services reported that residents in assisted living facilities in Virginia have one of the highest levels of care needs in the country.

It therefore seems only appropriate that the Commonwealth act as a leader in establishing a level of competency of Administrators which is consistent with the residents needs.

The current national exam establishes an entry level knowledge base which measures competency of a candidate. It is from this knowledge base that the administrator is able to read, understand and implement the spirit as well as the letter of the state regulations.  A state examination based on the regulations would have to be changed whenever the regulations changed or a technical advisory was issued. During the proper regulatory phases of the proposed assisted living facility licensure requirements, the merits of two exams as well as which type of exam i.e. national versus state were thoroughly discussed by a broad range of constituents. The final decision of the majority of constituents in the Commonwealth of Virginia was to implement a single national examination. I strongly suggest that we help facilitate the process.

Edward Owen, LALA / LNHA

Administrator

Masonic Home of Virginia

Instituting a national exam for ALF administrators would not be wise in Virginia. Virginia already regulates ALFs and credentialing for administrators of those VA regulated facilities should correlate with the VA ALF regulations. Since states license/regulate facilities, it would be more appropriate to have credentialing of administrators occur at the state level since there is not a national consensus on regulations for ALFs or even what the definition of an ALF should be. As in other licensing/credentialing arenas, over time when consensus is achieved it may make sense to have a national exam adopted to allow for cross-state application but for now that would not be appropriate.

I greatly oppose the requirement of a national exam for Assisted Living Administrators but do support a state exam based on the regulations that govern our industry in Virginia. 

There are  three points I would like to make. First a state exam based on the state regulations that govern our industry in Virginia would establish basic knowledge competency of the regulations as well as the ability to read, understand and implement the same regulations that we deal with on a day to day bases in our facilities. These established regulations give us the foundation for providing good quality care to our residents.

Secondly, the cost  of the national exam is a prohibitive factor for most current administrators and I fear that the industry will lose quality people especially with the shape of our current economy. We must protect our small pool of candidates who provide quality care  currently in our Assisted Living industry in Virginia.

Thirdly and lastly, Assisted Living  facilities in Virginia  are not regulated by the federal government..  A state exam would make more sense as we are regulated by the state.

Licensing administrators is a good idea, but basing the examination on anything other than the regulations we are required to follow is confusing and may cause many good and qualified administrators to no longer be able to provide a much needed service. 

As administrators leading our teams to provide quality care to the seniors entrusted to us is a large responsibility.  We spend a lot of time keeping abreast of the regulations we are required to adhere to.  I have taken some practice exams  and the questions that I have answered incorrectly have been the ones that are based on federal regulations that do not match Commonwealth of Virginia regulations which is frustrating.  Please consider basing the administrators exam on Virginia regulations.

Reapectfully,

Wanda Pruett

Commonwealth Assisted Living

I agree with Governor Kaine in calling for a review of three importnat areas; the need for a national exam in addition to the Virginia state exam, the amount of administrator in training hours and certainly the matrix of experience and education required.

Respectfully,

Brent D. Russell

I agree with the Governor in calling for a review of three important areas.  The need for a national exam in addition to the Virginia state exam, the amount of administrator in training hours, and the level of experience and education required for new administrators.

I am writing on behalf of Emeritus Senior Living.  Emeritus provides assisted living and memory care services at more than 280 communities in 37 states.  We serve approximately 700 residents in nine assisted living communities in the Commonwealth of Virginia.

Emeritus fully supports Governor Kaine's recommendation to eliminate the national administrator’s examination requirement, and replace it with a state exam based on the specifics of the Virginia regulations.

The assisted living industry is regulated in all 50 states, but not at the federal level.  Thus, there is no real standard for setting a national exam.  The current national exam reflects the skilled nursing facility medical model, which lacks relevance to social model that sets the design for assisted living communities.  The state exam ensures that assisted living administrators have skills and competency with appropriate focus on the requirements of Virginia regulations.

The financial requirements of the national exam are significant.  We support the Governor’s position that we should strike a balance between ensuring quality administrators and allowing an adequate pool of administrators from which to draw.  We should not be setting unnecessary cost disincentives to potential administrators who are willing to provide this much needed service to Virginia’s senior citizens.

We note that several administrators have posted comments in support of the elimination of the national exam, but requesting that those who have already passed the exam be given “grandfather” status.   We support that position as well.

Thank you for the opportunity to comment on this important proposal.

Melanie Werdel

Executive Vice President of Administration

Emeritus Senior  Living

Seattle, Washington

I think the existing examination poses a hardship on the small facilities.  I have been a licensed administrator for 10 years.  I have a college degree and a Masters Degree in Social Work.  This has been acceptable.  My two supervisors have neen licensed administrators for  8 years. 

There should be a "grandfather" clause for these exceptional cases. It is a very expensive for a small owner( 8 residents each) to have to test their "administrators" who have been licensed administrators for the past 8 years.  What don't they know that they need to know now???

Thank you.

Pearlbea Labier

Owner of Labier Assisted Living

Dawes House

David Lane

703-352-2499

I am in favor of eliminating the national exam for ALF administrators and require only a state exam.  AL communities are regulated at the state, not national level.  There are no national standards upon which to base a national exam.  The NAB exam is costly and does not test on the state level.  Virginia is one of only 3 states currently requiring both a state and national exam.  The additional cost of the national exam could very well discourage capapable, competent and caring providers from becoming administrators.

As a Registered Nurse and a Licensed Nursing Home Administrator, I support the petition to eliminate the national exam and replace it with a state exam for the following reasons:

1.  Assisted Living is regulated at the State level and should be tested by a State exam based on State regulations.

2.  A national exam without one set of federal standards is unwarranted and not relevant to assisted living, especially if it utilizes a nursing home model.

3. The additional cost of the exam and study guide places an undue burden on those already struggling with the sharp increases in the cost of fuel, electricity, food and high cost of living.

4.  Each and every day, throughout the Commonwealth, quality care and services are being delivered in Assisted Living communities by competent, caring Executive Directors without this requirement.

Thanks in advance for your thoughtful consideration.  A re-alignment of licensure requirements with the Governor's mandate would be much appreciated.

Silva K. M. Gerety

MPA; MSN; RN; NEA-BC; NHA

It is my understanding that the National Exam will cost 400.00$ !.  I am already paying 275.00 just to take the training required to take this exam.  The cost of living is at an all time high and I am finding it hard to financially comply Va State laws just to stay in business.   There have been so many changes and all seem to be causing a financial burden and a threat to my business with the possible deision of having to lay some of my dear employees off. I am already avoiding raising care costs and trying to keep daily rates at a comfortable level, in order for residents to afford their care  without worry.    In order to continue a business that I have succesfully ran for 12 years, continue quality of care for so many residents through the years (with excellant references), We really need to work together here and keep costs of operation to a minimum. I really do not feel that a NAtional Exam is necessary.  Please.......Please......... reconsider a STATE Exam opposed to a NATIONAL EXAM. There are numerous small private homes like myself that are being beat up with too many stringent laws , causing a discouraging factor to continue a much needed service.  I would really appreciate your re- consideration.

Sincerely,

Annette NAff, LPN, Owner

I have been a part of the assisted living industry practically since it's conception in the early 90's....I concur and support the petition set forth by Gov. Kaine that we should eliminate the National exam for licensure of our Directors and replace it with the State exam.  The NAB exam is a nursing home model that is not relevant to the operations in a Virginia Assisted Living Community.  Assisted Living is regulated at the state level and I feel should have a state exam that would certainly be more pertinent to our state regulations.  Thank you for your thoughtful consideration for the many Directors who are giving our Seniors professional and compassionale care every day.

I wanted to express my concern about the Federal administration of the Administrator's Exam for licencing. Since the Assisted Livings are regulated by the state, I feel the exam should also come from the state. Recently, a small home closed because they were unable to find an administrator who was qualified, was willing to meet the new standards and met the high standards of the owner for an administrator. We do not want to loose the dedicated administrators that we have.

I am in favor of a state exam vs a national exam for the following reasons:

To Whom It May Concern,

I am writing this letter in response to the petition to eliminate the requirement for a national examination for licensure of the assisted living facility administrators and replace it with a state examination. I am in support of this petition . I have been an Executive Director/Administrator for the last  six almost seven years and I am appalled that the state of Virginia wants to require an exam for assisted living facility Administrators based on Nursing Home Standards. I STAND for excellence in quality care that we provide to our seniors in the state of Virginia in our Assisted Living Communities and believe that this requirment is unfair and needs to change. It is an unfair requirement, Assisted Living Communities are NOT nursing homes and I feel that if I must be required to take an exam then test me on what I practice. I feel that the state of Virginia is feeling the financial strain of the impact that assisted living facilities are creating because the majority of us to provide excellent care to the seniors of Virginia and are better at providing personalized, family oriented care. I  do have to question the state's motive for the push or rather the effort to push out the assisted living facilities in Virginia, hey the people have spoken in re: to who their choice of providers are.and assisted living facilities are winning.. We will not conform to the Nursing Home philosophy, this is not who we are and no matter what the state tries to push we are who we are and that is people with heart's, determination, and dedication for the seniors we care for, in the end they are all that matter and they are the ones who will be on the losing end should this regulation not change. You can't tell me, my residents and their families, and my staff, that we are not qualified to do what we do each and everyday in our community because we don't have a piece of paper, licensing us based on nursing Home standards and philosophy, this is not what makes the difference , the owners, operator's and staff that are here each and everyday interacting with these seniors , giving of their heatrs,is what makes the difference, not the state's required license and not some test based on completly different philosophy's, statndards and regulations. Test us on hat we do and who we are and that is the heartbeat for our seniors in the state of Virginia. Thank you for your time and consideration in this matter, my fellow collegues, residents, and family members will continue to speak out about this matter and continue to stand and fight for what is right for our seniors that have been entrusted into our care.

Theresa A. Taplin, LPN

The Assisted Living industry as a whole is in favor of replacing the National exam with the State Exam.  This licensure requirement of the National exam is costly and would not be as benefical to us in our operations as would be the State exam.  I am asking that you reconsider and support this petition along with Govenor Kaine.  I appreciate the opportunity to voice my concerns.

To Whom It May Concern

I am writing this letter in support of the petition to replace the National Administrator Exam with a state exam. We are regulated by the Department of Social Services and thus should be tested on those standards. I don't feel that this exam will better qualify anyone in being an Administrator of an assisted living facility in Virginia nor will it provide for a higher quality of care for the seniors that we serve. This regulation is only making it harder to provide care and taking away valuable resources and funds that could be better used in providing care to these seniors. If this regulation should become final and there is no change to this standard, who will be left to care for the elders of our state? I don't understand why we are trying to be made to conform to a nursing home way of doing things, we are not in the nursing home busines, we are in the business of caring for seniors. Our facilities are not of the institutional setting, we are a homelike, family oriented setting who lives and breathes quality care to the residents we serve. I feel that this regulation needs to change and emplor that the state of Virginia strike to make a change before it's to late.

Sincerely,

Shelly Ruckman, RCC

I speak on behalf of not only myself, but a multitude of Executive Directors, that I have had the honor to work  with for the past 20+ years in the assisted living arena. Having supported multi site operations in both VA and other states throughout the East Coast, I find it appalling that assisted living Executive Directors are being mandated to take a test that neither pertains to the direct care of their residents nor the operation of their community. Expecting Executive Directors to sit for a nursing home examination would be no different than asking a skilled physician to change their speciality at another's whim!  Not only would that physician be asked to produce knowledge that he/she is unfamiliar with, but, more importantly, the mere task of asking for such an expectation sets a negative tone.  Requesting that our assisted living directors become nursing home administrators goes directly to the heart of what they do and who they are; professionals who chose to break away from the conventional and dedicate themselves to a better way of caring for our aging population. Take away their speciality and you take away their passion!

I support a state mandated exam produced by the state of VA that holds our Executive Directors accountable for the care of their residents.  This would be a fair and equitable process.  Having served in surrounding states and become familiar with various sets of regulations, I have personally observed the success of state required exams produced by state regulatory entities. After all, when examining the "big picture" the requirement of the NAB not only questions our Executive Directors' abilities, but doesn't it also question the ability of  DSS? The exact entity that the state has designated to hold our EDs accountable? Should they not have the right to develop the state exam?  I find this disconnect quite puzzling.

All of us in the assisted living field can continue to voice our dissent regarding this national exam and it is certainly evident during this public forum. But, let us break this issue down to one simple premise... if we force our colleagues to be what they are not, their heart will be gone. And no matter the words or sentiments that are expressed during this time, it will ultimately be our seniors that will suffer ...for that is why they and their families have chosen assisted living... for the heart.  Knowledge is powerful, yes, but I cannot teach someone to have a good heart.  Either is exists, or it does not.

Thank you for this opportunity to respond,

Ann Coda

Director of Human Resources, Training and Development

Greenfield Senior Living

As an administrator in Virginia, my focus has been since 2002, learning and operating under the Sate regulations. It is my opinion that the exam should be based upon the regulations under which we are required to operate.

Thank you,

Diane Coker

When taking the exam I found there was a lot of questions that pertain to Medicaid which we do not deal directly with.  Also there were questions regarding restraints and regualtions of height of certain restraints, which again we do not use as we are restraint free. 

TAssisted Living is regulated in all 50 states but not at the federal level.   Where would the standard come from to regulate this exam?   The nursing home model for the exam would not be appropriate.  The NAB exam would only exclude many potential candidates from the much needed arena of healthcare as related to Assisted Living. 

Virginia already appropriately regulates ALF. Bringing this to a national level will reduce the pool of administrators. We are assisted living and should not operate under the same regulatory as a skilled nursing home. Taking this national exam will not make any difference in the care provided in assisted living. Our faciilites operate in creating an environment that is not so regulated that it feels and looks sterile but more warm and inviting....homelike.

As a new, but successful and compassionate, professional to the assisted living and health care industry and one who had not invisioned a career path in this direction (have been a marketing director and/or graphic designer for the past 20 years), I can honestly say that had the new regulations been in place when I began two years ago, I would not have considered continuing in this profession.  How many others are thinking the same or not considering working in Virginia due to the stringent licensing requirements?

I believe first and foremost the question that needs to be answered regarding any state regulation governing assisted living - but especially in reference to the national exam for administrators is this:  How will it effect the AGING/ELDERLY CITIZENS OF THE COMMONWEALTH OF VIRGINIA?  Will there be sufficient administrators to oversee communities to provide the housing that is and will be required?  How many current administrators will retire or populate into another career path due to the current regulations?  How many of these administrators are at smaller, "mom and pop" communities that provide much needed care for residents on medicaid or in the lower income strata?

Further, the assisted living industry is regulated by the Commonwealth of Virginia, not by federal standards.  If the concern is to ensure qualified administrators, then wouldn't a state exam - focusing on state regulations - be a better path to take to obtain the goal?

·         ·         Only two other states require the national examination to license assisted living administrators. A third state required the examination until recently when they changed their regulations to require a state examination.

·         The cost of the national exam and study guide is approximately $400, which is cost prohibitive for many individuals who must pay the costs out of their personal pockets. This financial restriction will result in the loss of compassionate and outstanding administrators who can not afford the costs.

The purpose of a national exam, to insure qualified administrators, is a valiant one.  However, as the current generation of assisted living residents would say, you don't want to cut off your nose to spite your face.  A better solution is out there, we just need to continue to search for the answer.  A state focused exam?   A more uniform inspection process throughout the state may help spot inadequate administrators?  Enhanced training/continuing education requirements for administrators?

In closing I also would offer this:  an exam of any kind only reflects the knowledge that anyone can aquire through study, "book sense".  What is doesn't show is the compassion, the caring, the love someone has in their heart for the people we take care of every day - the desire to do the right thing for them each and every day.

Who do you want taking care of your Mom, Dad.........or even you?

·       

I believe that the exam should be structured on Virginia's DSS regulations not the national regluations.  

Thank you for the opportunity for me to express my concerns regarding the licensure regulations of administrators in assisted living communities throughout the Commonwealth of Virginia.

My concerns have nothing to do with being licensed.  I am perfectly agreeable to the fact that all administrators, myself included, be held to a standard and expectation set forth by the Commonwealth of Virginia.  Our residents, families and industry deserve to have leaders who exhibit skills that make a difference, ensure dignity and self-expression, show responsibility for our actions as well as demonstrate integrity. 

What I am discouraged about is the fact that we must take a comprehensive national exam and not state specific exam based on what, we as administrators in the Commwealth of Virginia, are accountable for.  How does preparing for a national exam, that is mearly for licensing purposes only, make us better administrators in Virginia? 

I am being asked to go in and take a test on national, not state specific regulations and then be judged by merely a pass or fail score.  Does this truly demonstrate whether or not I am qualified to be an administrator in Virginia?  I am a successful and devoted adminstrator for the past three years and I currently hold a two year license.  Test me on our state regs and I have no quarms about taking this exam.  Test me on someone else's regs, then that is where the issue lies.  You don't make a student take the Cailfornia SOLs in Virginia so why make an admistrator take a national exam?  Especially when only four states out of 50 take this particular exam.  If this test was a Virginia exam, based on our regulations, then it would be completely acceptable.  It's what we as administrators are hired to do, it's what we are hired to comply with and it's what we are hired to be accountable for in our buildings.  Having a national exam, for lack of a better term, is stupid!  

As I mentioned, there are only four states in the country with this absurd exam.  Four!  Plus, each state has its own specific regs.  It makes absolutely no sense!  What benefit to our industry or piece of mind will our families and friends take in knowing that all of us had to fill out pages of an application (which is another issue) and spend hundreds of dollars to take a test that doesn't even apply to what we specifically do in our state?

This is politics!  It truly does not benefit our residents to take a non-state specific exam.

My other concern is the application process.  Personally, I feel like I am applying for security clearance.  I understand we need to be registered, but the details are a definite overkill and seem truly unnecessary.  

I would greatly appreciate reconsidering replacing the national exam for a more job specific state exam.  If the object is to have better runned assisted living communities throughout the Commonwealth, then have a state exam.    

I agree with Governor Kaine in calling for a review of three importnat areas; the need for a national exam in addition to the Virginia state exam, the amount of administrator in training hours and certainly the matrix of experience and education required.

Respectfully,

Courtney Lavander

Executive Director

Sunrise of McLean

Assisted living is regulated in all 50 states, but not regulated at the federal level. Therefore there is no one set of federal standards upon which to base a national exam. This exam, prepared by the organization that creates the Nursing Home Administrator exam, uses a nursing home model that is not relevant to assisted living. Labor shortages in all areas of health care, including assisted living, have been well documented, and all indications are that the trend will continue. The pool of potential employees will continue to shrink as demand to provide services continues to increase.  Promising executive directors living in the State of Virginia will go to neighboring states where this cost-prohibitive regulation is not in effect.  We would like to raise the bar for our Executive Directors that serve our residents and not limit our options.

I agree with Governor Kaine with regards to calling for a review of several areas.  The review of the national exam in additon to the VA state exam, the amount of hours needed for administrators, and the  levels of education and experiences.  Thank you for your time and attention to this matter. 

As much as licenses and certificates are important tools to determine someone's level  of competence and qualifications, they can actually be misleading. We have to be careful when we are over stressing this need in the service industry, more especially when dealing with seniors. This is due to the fact that leaders in this industry apart from their technical abilities, there is the need to posses an immeasurable sense of passion for human life to promote the quality of life for seniors on a consistent basis. I believe strongly that overregulating this industry is not the best way forward.

I have served in the assisted living industry in Virginia over the last 25 years, and about 10 of those years as an assisted living administrator.  I recently took and passed the national administrators exam, and was concerned by how gneric the test was.  It is my understanding that the Commonwealth of Virginia is one of the first states to have comprehensive licensing standards for assisted living, and it is my opinion that the test for administrators in the state should be geared towards a comprehensive knowledge and understanding of the VA regulations, which would encompass the general assisted living practices on the national exam as well.  I think this approach would enhanced the quality of life of our Virginia residents in assisted living, as well as team members working in assisted living.   Thank you for the opportunity to comment.

I am concerned about the the regulations being considered by The Department of Health Professions as it relates to the licensure of Assisted Living Administrators. I have served in the Senior Living industry for over 30 years, I have been licensed as a Nursing Home Administrator/Assisted Living Administrator in three states, and I have had operational oversight in over 30 States nation-wide. I believe in licensing, it is very good for the credibility of our industry. I do have concerns though about a national exam, I feel the state exam would be more than adequate. There needs to be a balance in the required amount of administrator in training hours so we do not discourage anyone from entering the industry, either due to time or cost issues. Lastly,we must be careful to assure the proper experience and education backgrounds of administrators to enable them to give quality care to our Residents. Thank you for your time and consideration!  Ben Decker.

I understand everyone's position, but for someone such as myself, who is all prepared to take the national Exam, I feel strongly that it is unfair to now expect a State exam to be administered. This should have been taken into consideration earlier, before you made it mandatory to sit for the National exam. If the rules of the game are going to be changed at half-time, than a fair referee needs to be in place now! Assisted Living regulations are so over the top in Virginia, administrators for Assisted Living will not be necessary ,as we will all be converted to nursing homes before long! The folks that create these regulations need to take a step back and realize why assiste living was founded in the first place..to oofer a CHOICE for the resident and how they want to live the last of their days!