This regulation should include a grandfather clause.  Also, there are alot of administrators that have already completed the ALFA training & exams.  This should also be recognized as an approved course.  The application, preceptor, renewal fees are costly.  The facilities that still accept the auxillary grant residents are decreasing due to the low reimbursement for cost of care and now Dept of Health Professions is proposing additional fees to license administrators.  In reference to the course Irvin Land offers;  if the board does not have the statutory authority to approve this course or any other that would quality perspective administrators, then who does?  What are requirements for someone who is a licensed administrator in another state with 20+ yrs in health care who wishes to become an administrator in VA?  Please take into consideration what impact this regulation will have on the residents & facilities if you don't include a grandfather clause and approved courses to become a licensed administrator.  Continuity of care!