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