Virginia Regulatory Town Hall
Agency
Department of Social Services
 
Board
State Board of Social Services
 
chapter
Standards for Licensed Assisted Living Facilities [22 VAC 40 ‑ 73]
Action Licensed Assisted Living Facilities Regulation Comprehensive Revision
Stage Final
Comment Period Ended on 12/13/2017
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12/13/17  9:56 am
Commenter: Jon Aldridge, Mennowood Retirement Community

22VAC40-73-1130: Special Care Unit Staffing
 

Mennowood Retirement Community is a Christian, not-for-profit assisted living community offering independent living, assisted living, and memory care in Newport News.  Love, service, and compassion for our residents is our calling and our mission.

We firmly beleive that his requirement places an excessive burden on assisted living communities when the community 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 needs as assessed in the UAI and carried out in the 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.  On the third shift (11p-7a) a majority of residents are asleep and require minimal care beyond monitoring.  

This requirement assumes that more staff will result in a higher level of care.  In truth, the UAI and ISP should drive the required staffing levels based on overall resident acuity. 

Lastly the cost of addional caregivers cannot be ignored. 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. 

In sum, we offer that this requirement should be reconsidered so that any staffing requirements are driven by resident care needs.

Thank you.

CommentID: 63308