The proposed regulations fail to address those indvidiuals who have been working in upper management  but still cover facilities for intrim purposes and are the trainiers of the administrators for a company .  Companies hire former administrators strickly for these purposes and all that I am familiar with are well seasoned administrators who have moved to the next level of management.  The proposed regulations penalize them for moving  to the next level in the management of assisted livng. These individuals have not been the adminstrator of record in any facility in  the last three or more years  I think that these individuals should be considered the same as  those administrators who have been adminstrators for the past 2 years and should be able to sit for the exam as those who meet the criteria of being administrator of record for at least the past 2 years.