Coordinated Services Management, Inc. represents several non-profit owners who have assisted living memory care units.  Providing the highest level of care, comfort and safety is the primary mission for each of these owners.  This requirement places an undue burden on assisted living facilities by requiring additional staff requirements, even when the assisted living facility has determined that the facility is adequately staffed to attain and maintain the physical, mental, and psychosocial well-being of each resident as determined by resident assessments (UAI) and individualized service plans (ISP).  If there are additional direct care staff in the building and the community has determined that there is adequate staff readily available to assist with emergencies in the special care unit, then this requirement of additional staff is unnecessary.  At night, in particular, a majority of residents are asleep in their beds.  This requirement presupposes that more staff will result in a higher level of care when the UAI and ISP should drive the required staffing levels based on overall resident acuity.  The average cost to add one staff member to one facility to meet this requirement is approximately $43,680 annually.  This will result in an increased rent of approximately $2,080 per year per resident.  This requirement should be reconsidered so that any staffing requirements are driven by resident care needs as determined by the UAI and ISP.