Has any thought been given to grandfathering those people who have held the position for 5 or more years and who have successfully completed an ALFA course with a certificate designating them as an Assisted Living Administrator and also credit for those who have earned the designation of Certified Senior Advisor?  What about small homes that have been operated by the owner for 25-30 years-will they be grandfathered?

What is wrong with LPN's teaching a Medication Aide Training Program? 

I really feel that the impact study needs to be reviewed.  With that proposed, the requirements for administartors will prevent many homes from being able to afford someone that meets the proposed qualifications.  What are we trying to gain from this?  Changing the requirments for the administartor will not impact the true areas that need addressed.  The areas of concern are not with the actual educational requirements of administators, but rather, with those that hire them.  These proposed reg's are far too reaching.  Look at most violations that occur in an assisted living home - would stronger educational requirements for an administrator lessen the violations?  No.  Thus, what need is it to financially burden assited living homes with increased costs that will not correct the problems at hand ?  I ask that a stronger review of these matters be made to prevent yet another over burnden policy being put on facilities that cannot afford any further burdens that will not correct most problems at hand. 

It is my opinion that if the regulations require additional credentials for new administrators it will cause an undue financial burden on providers, especially smaller providers.

I feel that there should be an alternative for those who have worked their way up the ladder and have been promoted due to their hard work and dedication to the care of their residents.  College is not feasable for everyone.  Why can't you implement a certificate program that is more extensive and require a certain amount of internship hours instead of a college based program?

The term "Domain of Practice" is referenced but not clearl;y defined. 

Strictly taken, unprofessional conduct under points #1 and #2 could be seen as any citation of any violation. This could be more effective if the violation(s) results in the approval of a sanction or negative action such as a license denial or revocation.

For administrator in training courses, there should be a distinction between that specific role and working in an ALF as a direct care staff. Current ALF standards also reference experience in a supervisory role as a qualification for administrator which may not be as an AIT.       

"Leadership and governance" are not defined or explained.

There should also be some education/training/experience in regulatory management or business management in a regulated environment.

 

I'd suggest there be license types or classifications. A "general" license could be issued to someone with minimum qualifications (education or experience to include current ALF administrators) for an ALF without a special care unit. An "advanced" license with more education or experience/training in dementia could be required for an ALF with a special care unit.        

I have just starting the class for ALF adminstrator, my opinion this could be very costly for all the small business.

I am presently enrolled in the Assisted Living Administrator's Certification class approved by the Department of Social Services.  I am able to take this course through a scholarship provided and approved by my employer.  I am a middle-class Mom of a special needs child, who requires alot of care.  This puts a financial burden on my family.  I have to work full time and can not afford to go to college.  I ask that you remember other people who can not afford to go to college or are just not college going kind of people, for whatever reason! PLEASE! Create a licensing track that doesn't include college credits, but the Department of Social Services approved Assisted Living Administrators' Certificate! 

I feel that the regulations proposed is creating a very drastic change. Please consider the whole spectrum of  the different types and sizes of Assisted Living Facilities.  We all have to realistically to be able to meet the requirements for licensing, not only as individuals but as facilities, too!

I feel like that new requirements for ALF Administrators are to demanding.  I am enrolled in a DSS approved ALF Administrator progrma because I do not have the time or the financial means to go to college for the hours the new regs are insisting of.  I run a small 31 bed AG facility who needs constant attention from me.  With that alone there is not much time left in an average day to go to college.  Plus there are alot of people that I know that are great Administrators but awful college students.  Why can't we leave the regs like they are so pople who can not afford or does not do well in college settings be allowed to take a DSS approved course and be probably one of the better Administrators that we all know.  In considering this please remember that it is not how you get the education that is important it is the heart and compassion someone has as well as the determination to be the best Adminstrator he or she can be.

I appreciate the complexity of the task undertaken by these proposed regulations. As a future Assisted Living Administrator I have spent some time studying the various pathways toward licensure outlined therein. I hold a bachelor's degree from the College of William and Mary, in Biology, and am in the process of completing the Certificate course offered by the Assisted Living Credentialing Center, but I am not the administrator of record at my community. I am the Marketing Director. As I read the licensure requirements as proposed, I would be required to complete an internship under the direction of either my Executive Director, a licensed Nursing Home Administrator, or my Assited Living Director, who is eligible for licensure since she has been the administrator or record for two of the past three years. Either of these preceptors would have to be registered with the Board, and a written plan for my internship would have to be approved before I can begin my training. I am very willing to undergo the preceptorship; I find it entirely reasonable. My major concern is that in section 18VAC95-30-100 there is a reference to the Domains of Practice that should be included in the internship planning, and the section where the Domains of Practice are to be defined, section 18VAC95-30-160, defines the Domains so broadly I am having difficulty beginning the construction of a training plan. My assumption would be that the areas outlined in 18VAC95-30-100, subsection 3, part C, items 1-6, would be a good start. Perhaps a little more definition would be helpful to those of us wishing to begin the development of a training program before the regulations are finalized. Thank you.

I have currently enrolled in a state approved program for ALF Administrator by DSS. I think if you go through this course and pass your state test there should be a Grandfather Clause that that is all you need to maintain your license and your reqierd C.E.U.. If you enroll in the class after July of 2006 this new regulation would apply . I have been working in Long Term Care for twenty years in various positions. I have learned that it is not the education that makes you who you are, it's the experience. I have seen many administrators come and go in my time, some with a Masters degree that were the worst! So you trying to say that because he had his degree he would be a better administrator is appantly because you all sit at your desk too long and do not see the real world . I think someone who has worked their way up from the bottom would be the better candidate. Most administrators have never done hands on care for a resident and Assisted Living is suppose to be a social invironment not medical . If you are really concerned about the care and process, maybe you need to look at the survey process not how the person got the license. Consider making the license like a nurses license where any problems are reported to the Licensing Board and can be reviewed online.

 

JOHN ALLEN DIRECTOR OF  ENVIRIONMENTAL SERVICES

This regulation should include a grandfather clause.  Also, there are alot of administrators that have already completed the ALFA training & exams.  This should also be recognized as an approved course.  The application, preceptor, renewal fees are costly.  The facilities that still accept the auxillary grant residents are decreasing due to the low reimbursement for cost of care and now Dept of Health Professions is proposing additional fees to license administrators.  In reference to the course Irvin Land offers;  if the board does not have the statutory authority to approve this course or any other that would quality perspective administrators, then who does?  What are requirements for someone who is a licensed administrator in another state with 20+ yrs in health care who wishes to become an administrator in VA?  Please take into consideration what impact this regulation will have on the residents & facilities if you don't include a grandfather clause and approved courses to become a licensed administrator.  Continuity of care!

The proposed regulations are too complex to fully understand. Although the purpose of the changes are not clear, my experience of 10 years has taught me that the educational level of the administrator is just one of many variables necessary for the efficient operation of an assisted living facility. The education level and training already in existence through DSS is quite sufficient for the population we serve. If we compare the education level of nursing home administrators with that of assisted living administrators, we need to also compare the monthly revenue received by the two entities. I cannot imagine a nursing home administrator after receiving a very costly education from a college/university opting to be responsible as administrator of an assisted living facility with our present budget for public pay residents. 

If education equals efficiency, violations in nursing homes would likely be at an all time low. May I suggest we keep the present education level and training and increase revenue to each facility more in line with the actual cost to operate. This would afford each administrator the opportunity to hire dedicated, qualified staff, provide maintenance, and comply with other costly DSS regulations. More staff at the Division of Licensure to provide one on one consultation and training to administrators is vital to ensure compliance. The provision of internet self study courses in Client/resident care, Human resource management, Physical environment , and Leadership and governance would be a phenomenonal tool for administrators to  increase knowlege, advancement and efficiency while being physically present in the facility for emergency and other situations. 

Your proposal would force medium and small facilities out of business, thus causing a major disruption of services to the consumer. Consequently, the consumer would be forced to be warehoused in large instutionalized settings, rather than a more home like environment, thus limiting their right to choice.

 

The regulation as proposed will neither serve the residents nor small to medium facilities for several reasons. As Mr. Harvey points out, there are too many undefined items. There also appear to be subjective areas, particularly if the board (comprised by a majority of nursing home - not AL - administrators) is to review each administrator's educational background on a class-by-class basis to determine their appropriateness for the position. There is no grandfather clause for those who have considerable experience in assisted living facilities but lack the educational background, or for those with the experience but an education in, say, general business rather than healthcare. Additionally, if the Board cannot approve a course, who will determine what is the appropriate education?

As for the Medication Administration requirements, like the Administrator requirements, many people who have extensive experience in the position may find themselves changing careers due to the cost and time involved in being registered under the proposed regulations. It appears the new regulations would give preference to young inexperienced people just getting the training with the new reegs in mind rather to those who have solid experience in the field.

Please remember that ALs are NOT nursing homes, and that many employees and perhaps even some companies may not survive these proposed changes.

These new regulations regarding educational requirements will inevitably cause a great financial hardship on the smaller facilities and most likely will cause many to close. What about knowledge gained through experience? I am one of those with no letters after my name on a piece of paper. I have learned through hard work and lessons learned starting out as a nursing assistant many many years ago.I have held several positions in the health care industry and my employer realized my value and put me into an Executive Director role in one of their communities. EXPERIENCE should be considered, not just educational background. As far as the medication techs, I agree that stricter guidelines should be incorporated. Maryland has an excellent system for Med Tech training. So much so, they are used in Nursing Homes, not just Assisted Living Facilities. Medication Administration should not be taken lightly. I have seen many, many infractions on a survey with regards to Medication. This could be virtually eliminaterd with better training and stricter requirements.

I strongly feel that if an individual recieves training from an accredited program such as the American Assisted Living Caregivers Credentialing Center ,Assisted Living Administratration program he or she should have sufficient knowledge and traing to be an effective and efficient administrator.This is in my opinion a program that readily prepares one for all aspects of becoming an administrator. I feel that the proposed regulations are not necessary.

 

I am currently attending the state approved course for administartion of an assisted living facility. I do not currently have a degree, however I have worked in assisted living for approximately 8 years(as C.N.A, Med Tech, & Activities Director)So to say in short I have climbed the ladder and learned alot along the way. Would it be feasable to take in account all the hands on experience I have recieved.

Another possible idea I would like to express. Would it be possible to allow the current administartators to stay in there positions but require them to accomplish certain task before a time period so they may stay in there role and continue education.

I do believe that school is great, however I do believe that the hands on experience that i have recieved should equal if not orverdue time in class,knowing all regulations and how to manage all books are required regardless if you go to school or not, but the social interaction with the public and residents may only be generted by hands on experience.

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. 

I feel that the board needs to recognize and take into consideration, the background (experience) of administrators, as well as the education level or years of being an administrator.  I have been an administrator for 1 year and by July 1, 2007, it would place me at one month shy, of being able to sit for my license.  I have worked in long term care since 1998, fresh out of college and that is all I know, and to place a regulation that would not consider my experience, and or my current role as an Executive Director of ALF, is not satisfactory.   I hope the board takes into consideration, not only what classes the individual had taken while in school, whatever how many years ago, but the work experience, after all that is what really matters.