Good evening, I thought the deadline for public comments ended at 5 pm until I saw 11:59pm. I would like to continue on the Regulations that for 3 Residents we must have 2 Staff in all shifts. As I’ve mentioned earlier, it helps lower the incidence of Falls but does not eliminate Falls. Somehow in the Older folks lives it is bound to happen despite the vigilance. It is also not cost effective. In my case, nobody wants to work for me less than  $20 per hour. For 2 Staff I pay $980 a day. With a current census of 3 Residents paying only $10 per hour, how can I make a profit after paying “mortgage, utilities, building and grounds maintenance, car note, utility, bills, house insurance, liability insurance”. How come the Regulation is not applied to big corporations/facilities who still has the Staffing Ratio of 1 CNA to 8-13 Residents during daytime and Night Shift 1 CNA per 30 Residents. And if 1 Night Shift CNA calls in sick, it would be 1 CNA per 60 Residents.

I need clarification on the Regulation “Medication Review by a Licensed Medical Professional”. How come we Registered Nurses are not allowed to do that when in fact it is in our scope of practice. We do that all the time in many ways such as when when we do Medication reconciliation for admits from hospitals and other facilities and when adverse medication reactions happen and when desired therapeutic effect is achieved. For smaller facilities like hours, doctors don’t come every month to renew orders because we do not have Medicaid beds. Physicians do that every month when they renew orders for the next months MARs at big facilities that has Medicare and Medicaid beds. Our Residents meds are only reviewed by Physicians when they go for checkups every 6 months. Every time I send a copy of the Regulations to the Primary Care Physician, they make changes on the meds per our promptings and advocacy but they still do not label them as “30 days, 60!days or 90 days medication review”. Dept of Health Professions also send memos to Private Practices/Primary Care Physicians so that Patients under their care who reaides in Assisted Living Facilities would be compliant.

Liability insurance: I disagree with the directives that we have to tell new Admit clients, their POA and families that we have a liability insurance and to tell them that they would get paid $500, 000 per occurrence should they decide to sue us. That is such a set-up because that happened to me. Luckily, upon investigation by Dept of Health Professions, it was established that the frivolous claims of the family is untrue. But imagine all the stress we went through with the threat of losing our professional and business licenses. We had to provide all 2 years documentation and the claims they said happened over 2 years ago. That just showed that the 2 years statue of limitations does not protect us at all. We also had to provided proof of Nursing trainings and CEUs for 32 years of our progessional practice. Yes 32 years of documentations had to be dug up because the Resident’s family wanted the $500,000 per occurrence that I told them.

We dedicated our lives to taking care of the vulnerable Older Adults but the changes in regulations are making us re-think of our purpose in life and changing of profession and make us quit. I’ve been trying to sell for over 2 years now but the interested people who want to continue the ALF business are not granted “commercial loans” because the Banks applied the current Assisted Living Standards/Regulations to their criteria/requirements which include those mentioned in my earlier comments today which I would repeat: 

New regulations only allow a Nurse or a Doctor to start a small ALF business. I had RNs, Nurse Practitioners and Physicians who want to buy my ALF but they were not granted commercial loan because they are required to have prior 5 years prior experience operating a facility. Well hello! How can they start when they are required to have a prior 5 years experience? 

They are also now required to have a Licensed ALF Administrator or become one, but the trainings are 6 months to 2 years because there is no set in stone curriculum. That means they have to give up their careers, put their lives on hold and do a term that is like going for a Masters Program or an Associate degree. The same Administrator regulation is adapted also by the Lenders. I that for sure as there were instances that I was asked by these prospective buyers to go with them to the banks as an assurance.

Lastly, no facility would tarin them as Administratos if they don’t work for them after their training. They go for training because theybwant to be a small ALF business owners. 

There are qualified, experiencwd trainors who were Admins, Suoervisors of 180 bed facility before butvare not allowed tobyrain would be Administratirs now because they are in a 8 bed facility. Why train in 20 bed or morw facility when they are just going to operate a 12 bed facility? The trainirs certainly know the ins and outs of a 20 bed or more facility because of they used to work there.

Thank you for listening. I hope there would be more favorable changes that would nit just help small businesses so thatvthey won’t quit like I do and sobrgat also new good hearted people can start/go in the industry because there are still good hearted people who are concerned