To whom it may concern:

Our industry has worked very hard to ensure that all Administrators and candidates ultimately meet the identicle requirement necessary to become licensed, which is to successfully pass an examination that covers a broad domain of subject matter.  To think that any profession (ie, Registered Nurses) would consider themselves any better prepared, to the extent that they would not have to complete the same competency exam, than anyone else with the same work experience is unacceptable.  Please respond to anyone who wants to challenge the Assisting Living Licensing exam or claim exemption from taking it that they may do so if they successfully complete the NAB Nursing Home Licensing Exam.  To continue in the direction of quality care and leadership, please hold everyone to the same standard.  Thank you.

I am a Registered nurse and have worked in the long Term Care field in a variety of capacities but i can honestly say that being an RN alone does not qualify a person to be a Administrator of Assisted Living.  It gives you a great starting point because of the medical background but does not give you any of the buisness management tools needed.   

I do not  think that just because you are an RN you should be exempt from taking the required test for administrator.  As mentioned before, we must all be held to the same standard or the state should look at grandfathering an administrator who has a number of years of experience or at least recognizing someone that completed a certificate course for administrator.  

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.

I strongly disagree with the proposal that an RN should be licensed as an AL administrator without taking an exam.  Certainly an Administrator would not be qualified to work as an RN without appropriate training and testing, and to allow this is not an appropriate practice.  Having worked with many RNs in the assisted living setting, I acknowledge that there are some who would probably be qualified to be Administrators, but this is due to their work experience and not their RN licensure alone.  On the other hand, I have worked with others who would clearly not be appropriate in that capacity, regardless of their expertise as an RN, due to their limited experience with management and/or assisted living regulations.  Ultimately, I feel we should all be held to the same standard.  If they are going to be exempt from the Adminstrator training, then, at a minimum, they should be required to pass the same exam that is required of everyone else.

I am an RN and an Administrator of Assisted Living that has fullfilled the current requirements. If I had not met the current requirements of on the job experience and a class that lead toward sitting for and passing the exam then I would not be able to serve my population.  Not even a bachelors in nursing covers the fiscal, and plant management aspects of adminstration that are vital to stay afloat in this economy.

I am writing in response to the petition to allow an RN to be exempt from the licensure exam for AL Administrator  I have been an RN for over 30 years and an LNHA for 4 1/2 years. Although my nursing knowledge base both from a management and clinical arena augment my ability to function as an Administrator,  it does not provide the comprehensive knowledge base required to be an administrator. There are multiple domains that an administrator must be knowledgeable of and expert at to be an effective administrator and many of these areas are not within the practicing base of an RN, such as food service, fiscal knowledge, physical plant operations, etc.  There should be recognition during the training period for the RN knowledge but I absolutely recommend that all professionals including RN's be held to a consistent standard and sit for the exam for the administrator license. There needs to be consistency in the standard of practice for any administrator.

I do not beleive just because someone is an RN they should be allowed to practice as an AL ADMINISTRATOR, the exam and the Lic. process was instituted to be sure that qualified people  would be in charge. The board exam covers a wide variety of issues that any person responsible for the direction and oversight of a facilityy should know. These key people are responsible for implementing and maintaining regulatory standards and many people are aware that having an RN does not provide you  the regulatory knowledge required.pe over this text and enter your comments here. You are limited to approximately 3000 words.

I don't feel an excemption of testing is appropriate or would serve our elderly communities best interest at this time.  The concern for the national shortage of nursing that we are facing is one of the best reasons to rethink this issue.  We need all the nurses to be available in their chosen vocation, and making an easier transition for them to become ALF administrators would only serve to increase our nursing shortage.  It is my hope that this will play a large factor in this current decision. 

Thank you

Audrey Clausing, LNHA