The

supports the petition to eliminate the national exam for licensure of assisted living administrators in

and replace it with a state exam for the following reasons:

1.  The requirement for a national examination is inapplicable to the assisted living industry:  Assisted Living is a state regulated industry.  There are no national regulations for assisted living upon which to test.  Despite being available and heavily marketed for more than a decade, only two states (Nevada and South Carolina) currently use the identified national exam for licensing purposes, with a third (Idaho) replacing it as a requirement this year specifically because it did “not test the applicant’s knowledge of the rules and regulations of Idaho.”  Currently 31 of 50 states use either a state examination or state approved training for certification or licensure of assisted living administrators, with the majority of remaining states heading in this direction.  

2. The nursing home format used for the national exam is inappropriate to assisted living:  In addition to the lack of national regulations upon which to test, the national exam has been rejected for use because it has been developed by the same organization that distributes the nursing home administrator examination – and formatted to the same nursing home “Domains of Practice”.  There is no evidence these domains best represent assisted living, a 95% private pay industry offering distinct services and specialties.  As one example, at least one study guide for the exam includes an entire section on Medicare, which does not even cover assisted living.  At the same time, the exam requires only minimal knowledge on individuals with Alzheimer’s disease, who are typically bed-ridden in nursing homes, but not so in assisted living.  There are 12 pages of regulations specific to providing high quality assisted living Alzheimer’s care in Virginia - knowledge of which would be required for a state, but not national licensing exam. 

3.  The requirement for a national exam in Virginia was not supported by the assisted living industry:  During the last public hearing on this topic the following participants spoke against use of the national versus a state exam:

·        The nation’s largest assisted living provider (Sunrise Senior Living)

·        The nation’s second largest assisted living provider (Brookdale Senior Living)

·        The nation’s largest assisted living association (Assisted Living Federation of America - ALFA).

·        The Commonwealth’s largest assisted living association (Virginia Assisted Living Association - VALA).

·        The nation’s only academic program in assisted living (George Mason University - Program in Assisted Living/Senior Housing Administration).

·        Numerous freestanding and multi-facility administrators and providers. 

The minority of participants speaking in favor of the national exam were organizations in which nursing home membership exceeds that of assisted living, those not directly involved in assisted living, or previously licensed nursing home administrators - who have been exempted from taking any exam. 

4.  The requirement for a national exam was not supported by the Governor:

Prior to the last public hearing Governor Kaine submitted a letter specifically stating, “I understand that only a handful of states require a national exam and feel that a state level exam could cover the necessary material.”  This recommendation was not taken by the Task Force assigned to determine which examination to use.    

5.  The requirement for a national vs. state exam does not utilize in-state resources.  The organization identified to provide the national examination is a private, out-of-state agency.  Numerous other states have used in-state resources to develop their state exam.  George Mason University, a state institution, offers the only academic curricula in the nation dedicated to assisted living administration.  The university stands ready to work with other state universities and colleges, the Commonwealth, and assisted living industry to develop a model state examination for administrators – providing Virginia a one-of-a-kind opportunity in this regard.   

As home to the nation’s largest assisted living provider, largest assisted living association, and only academic program, Virginia should be the national leader in moving the assisted living industry forward, rather than backwards to a nursing home model of regulation.  The Commonwealth should address the concerns of those directly involved in the industry to create the best model for licensing assisted living administrators – unique to the communities for which they are in charge.