The suggestion that either a licensed nursing home administrator or RN should be exempted from fulfilling the licensure testing requirements applicable to everyone else – including current assisted living administrators - is incongruent, and possibly an unfair employment practice.  In any exemption for individuals licensed in other areas, a singular class of employee is being provided an employment advantage over the existing class of employees (assisted living administrators), as well as other qualified but unlicensed healthcare professionals - such as hospital administrators.  The nursing home administrators issue is compounded because they are additionally exempted from the assisted living experience requirement, meaning they will not have had to even work in an assisted living community to assume an administrator position - even over experienced assisted living administrators. 

Such exemptions are the equivalent of stating physical therapists are automatically qualified to be occupational therapists (because the work is similar) - while simultaneously denying occupational therapists from being automatically licensed for physical therapy.  The Commonwealth would face a class action lawsuit if they were to attempt such a regulation.

The argument that either the nursing home administrator or RN license is inclusive of the skill set and information appropriate for work as an assisted living administrator is also incongruent.  The NAB Nursing Home Administrator exam is not the NAB Assisted Living Administrator exam, which NAB has gone to great pains to make clear, and as evidenced by their creation, distribution, and sale of two distinct exams.  Nor is it representative in any way of the NCLEX exam for nursing.  Under this scenario, virtually any licensed healthcare professional with any work in skilled nursing or assisted living may be able to claim exemption from having to take and pass the assisted living licensure exam, including physicians, social workers, physical therapists, occupational therapists, pharmacists, etc.  At some point, the ONLY individuals who may end up having to take an exam showing ACTUAL KNOWLEDGE of assisted living are the administrators who ALREADY work in it – a completely backwards proposition. 

The exemptions appear to be designed to address the critical shortage of administrators that will be created as a result of testing and AIT requirements that place significant barriers to entry for administrators in Virginia – and which were adamantly opposed by the assisted living industry.  Worse, they do so while penalizing the more than 600 perfectly good administrators who were already in place, and despite no credible evidence assisted living in Virginia is more dangerous than (in fact may be superior to) other states. 

More than 40 states continue to use the recognized and more applicable combination of education and experience as the foundational requirements for work as an assisted living administrator, vs. repeating the mistake of over regulation, followed by the layer-upon-layer of follow-up regulations we are already seeing with assisted living administrator licensing in Virginia, before it is even underway. Either EVERY individual seeking to become a licensed assisted living administrator in Virginia should be required to take and pass any required assisted living exam, or the exam should be REMOVED and replaced with an appropriate combination of education and experience.