Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Long-Term Care Administrators
 
chapter
Regulations Governing the Practice of Assisted Living Facility Administrators [18 VAC 95 ‑ 30]
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7/21/08  3:29 pm
Commenter: Randy Lindner, National Association of Long Term Care Administrator Boards

The Assisted Living Administrator Knowledge Base is Much Broader than State Regulations
 

First let me dispel the misconception that the NAB Assisted Living Exam is a Nursing Home Administrators Examination. It definitely is not. The NAB RCAL exam was developed by a task group of assisted living administrators from around the country and validated by a national survey of assisted living administrators from every state in the United States. The NAB exam is not a federal regulatory exam, it is a knowledge based exam designed as a tool to measure the entry level competency of assisted living administrators as part of a state regulated licensure program.

As I’m sure everyone here can attest, Assisted Living Administrators (ALAs) and the communities they manage are at the forefront of personalized care. Simultaneously, the care ALAs manage and provide is transforming as the population ages more healthfully. This transformation is increasing the attractiveness and demand for the independent and reassuring nature of Assisted Living Communities. As a result, the importance of the role Assisted Living Communities play in the greater health care field is at an all time high.
 
As administrators, ALAs are responsible for the well-being of their residents and the communities in which they live. ALAs must dedicate their time to leadership and management matters such as oversight of resident services, human resource managment, managing the physical environment, finance, relationships with residents and their families, employees, the communities in which they operate and legal requirements.  While obviously critical, familiarity with regulations is but one aspect of their broad responsibilities; responsibilities which collectively determine the success and safety of an Assisted Living Community.
 
The ALA licensure process should reflect and reinforce the importance of the multi-layered responsibilities required of an ALA. The NAB exam has been developed and adapted over the last 10 years to do just that. The results help guarantee that Virginia’s ALAs are best suited to handle the wide-ranging duties their profession requires of them.
 
While the NAB exam is designed to gauge an ALA’s professional competencies, it is written at a high school education equivalency level, representing the education levels of the majority of the ALA population. In addition, NAB conducts periodic job analyses to ensure the exam reflects the most contemporary professional practice. With these factors in mind, the exam is prepared to help ALAs operate in the changing landscape of long-term care while avoiding any disruption in the current supply of administrators available to serve the industry.
 
The national NAB exam is not something unusual in assuring the entry level competency of licensed professions. The majority of the professions in the health care field as well as most other licensed professions require the passage of a national examination. National exams are used because they have proven to be the most cost efficient, effective, and fair means of preparing professionals to meet the challenges of their specialized field.
 
When considering the impact of a state authored regulatory-only examination for ALAs, the cost to Virginia and to ALAs to develop such an examination must be considered. These costs would prove prohibitive and would force the Commonwealth to impose high and burdensome fees on its administrators. To do so would require a much higher per person cost to Virginia's ALAs or for the state of Virginia to subsidize the Assisted Living industry.
 
A professional exam must be valid, appropriate, and, perhaps most of all, defensible. In this aim, the NAB invested heavily in the development of its exam – including the initial job analysis, item bank development, and examination forms. In addition, it continues to invest more than $100,000 annually in item-writing workshops, new exam form development, and studies to ensure the exam meets the contemporary standards of the industry.  
 
Because of these efforts, the NAB exam is a valid and practical means of determining licensure. In creating the exam, the NAB contracted with Professional Examination Services (PES), a nationally recognized testing agency, to conduct the job analysis and exam development. The first job analysis study was completed in 1996 and was updated in 2004-2005. A task force composed of administrators representing diversity in key demographic variables including experience, gender, race, community scale, ownership (public vs. private), and geography participated. The task force reviewed all terminology and content in the 1996 document for currency. PES conducted a survey of one thousand ALAs from around the country to collect validation ratings on the contribution of domains, tasks, knowledge, and skills required of the ALA profession. All this was done to ensure the exam is current, fair, and produces qualified ALAs and safe, successful Assisted Living Communities.    
 
As stated, the NAB exam helps license ALAs that are competent administrators qualified in areas of community and facility management. To replace the exam with a regulation-only test would set licensure requirements far short of this target and would subject the industry to greater susceptibility to federal oversight. The use of the NAB exam helps prevent a scenario in which the industry is burdened with cumbersome federal regulations; regulations which would weaken an individual state’s right to oversee the industry and the ability of ALAs to appeal such regulations.
 
We believe that the Virginia Board of Health Professions, the Virginia Assisted Living Association, and the National Association of Boards of Examiners of Long Term Care share the same goal – qualified and competent Assisted Living Administrators caring for Virginia’s aging seniors in safe and secure communities. Utilization of the NAB examination as a component of a state regulated licensure program, is the most effective way to acheive this goal and to avoid federal regulations.
 
 
 
CommentID: 1914