The regulation as proposed will neither serve the residents nor small to medium facilities for several reasons. As Mr. Harvey points out, there are too many undefined items. There also appear to be subjective areas, particularly if the board (comprised by a majority of nursing home - not AL - administrators) is to review each administrator's educational background on a class-by-class basis to determine their appropriateness for the position. There is no grandfather clause for those who have considerable experience in assisted living facilities but lack the educational background, or for those with the experience but an education in, say, general business rather than healthcare. Additionally, if the Board cannot approve a course, who will determine what is the appropriate education?

As for the Medication Administration requirements, like the Administrator requirements, many people who have extensive experience in the position may find themselves changing careers due to the cost and time involved in being registered under the proposed regulations. It appears the new regulations would give preference to young inexperienced people just getting the training with the new reegs in mind rather to those who have solid experience in the field.

Please remember that ALs are NOT nursing homes, and that many employees and perhaps even some companies may not survive these proposed changes.