The proposed regulations are too complex to fully understand. Although the purpose of the changes are not clear, my experience of 10 years has taught me that the educational level of the administrator is just one of many variables necessary for the efficient operation of an assisted living facility. The education level and training already in existence through DSS is quite sufficient for the population we serve. If we compare the education level of nursing home administrators with that of assisted living administrators, we need to also compare the monthly revenue received by the two entities. I cannot imagine a nursing home administrator after receiving a very costly education from a college/university opting to be responsible as administrator of an assisted living facility with our present budget for public pay residents. 

If education equals efficiency, violations in nursing homes would likely be at an all time low. May I suggest we keep the present education level and training and increase revenue to each facility more in line with the actual cost to operate. This would afford each administrator the opportunity to hire dedicated, qualified staff, provide maintenance, and comply with other costly DSS regulations. More staff at the Division of Licensure to provide one on one consultation and training to administrators is vital to ensure compliance. The provision of internet self study courses in Client/resident care, Human resource management, Physical environment , and Leadership and governance would be a phenomenonal tool for administrators to  increase knowlege, advancement and efficiency while being physically present in the facility for emergency and other situations. 

Your proposal would force medium and small facilities out of business, thus causing a major disruption of services to the consumer. Consequently, the consumer would be forced to be warehoused in large instutionalized settings, rather than a more home like environment, thus limiting their right to choice.