Good afternoon Sir/Madam,

I hope all is well with everyone as we all try to achieve work and life balance. I am appalled by the direction the ALF industry is going mainly because of the changes in the regulations that affects small businesses like mine and those who would like to start a small ALF with the right heart and concern for our Aging population. It is now obvious that the new burdensome regulations for the benefit of big corporations. It is no longer about the “welfare of the Elderly and the overwhelmed families with little to no resources”. The burdensome new regulations also affect small Assisted Living Facilities like mine by prohibiting people from going to us and instead, clients are left no choice but to go to big facilities and corporations. Also new individuals with the right heart, motivations and good intentions are not allowed to start small ALFs because the burdensome new regulations. Are these new regulations influenced by lobbyists? Just an honest curiosity. The following are actual new regulations and existing situations that is prevalent across the state. For example:

1) New regulations only allows Registered Nurses and Doctors (abridged) to start new ALF. And even if they are Registered Nurses, Nurse Practitioners or Doctors, they “must have a prior 5 years experience operating one Assisted Living. So how can one good hearted competent Licensed Medical Professional Start a new facility when they are required to have a previous experience ? 

By this new regulation alone, people cannot go to small facility where Staffing ratio is great, instead the families are forced to bring their Aging loved ones to big facilities where daytime Staffing is one (1) CNA per 8-13 Residents during daytime and at Night Shift one (1) CNA per 30 Residents. If one CNA calls in sick, one CNA would take care of 60 Residents. This is not fictional as I had been a Nursing Supervisor for one of those big Corporations for 7 years whose Staffing grid is done by men in dress shirts and ties and nice suits seating behind a desk who has bo idea of the bedside situation.

I have seen too many Licensed Medical Professionals denied a “commercial loan” because of that new Regulation.

2)This 2nd changes is directly related to the above. Despite their credentials, they are also mandated to be trained and licensed ALF Administrators. They have no problems taking the exams but the trainings ranges from 6 months to 2 years as there is no set Regulations and curriculum for that. That is like taking a Master’s Program! That means the practicing Registered Nurse, Nurse Practitioner, Medical Doctor has to drop their careers, put their lives on hold  just to be trained as Assisted Living Administrators so that they can operate a 5-8 Residents small facility. This Administrator requirement is also adapted by “all” banks offering commercial loans.

3) The places they asked to train them would not train them because after being trained, they were told to work for the facilities they were trained. The big corporations said they would not invest their time in them if they would not work for them.

4) There are highly qualified and experienced Trainors for would be Administrators but they are not allowed to train them because the trainors work or owned only an 8 bed facility. Dept of Health Professions said the Trainors can oly train if they own, work in a 20 or more bed capacity as the new Regulations stated. Why do the would be Administrators be mandated to be trained in a 20 or more bed facility if they would be starting a small business with 1-8 Residents?  Some Virginia counties only allow 8 Residents based on a 5 acre well and septic lot.

5) The new Regulations mandate 2 Staff for 3 Residents. How can a small business afford to pay 2 Staff every shift for 3 shifts every day when the small business owner has only 3 Residents. Yes, the incidence of “Falls” had decreased but “Falls” still happen despite that vigilance.

There is still more, but my time is up as it is now 4 minutes to 5pm and today is the last day for comments. Thank you for the opportunity to make commebts. Thank you for your time.

Respectfully,

Charity