This topic is dear to my heart.  I began as an administrator in Virginia in the year 2000.  Obtaining licensure in 2008, when it became available.  Over the years I have witnessed colleagues with passion for senior living.  Each one with our own personal story and background.  I have always been baffled that experience was not considered in licensure in lieu of the educational requirement.  

I have seen LPN's that received their license through an accredited college complete the AIT program and be successful.  I have seen LPN's that received their license through a vocational school and not be qualified to complete the program.  Same skills, same or more experience, and certainly the same passion.  However, the limitations prevented them from becoming an administrator.  This scenario is common in candidates with varies backgrounds such as business office managers within senior living.  Most are the assistant to the administrator and have experience in all facets of the business.  Yet, their experience is not considered in the licensure process.  

Thank you for your consideration.  In an industry that we are seeing leaders retire and/or leave the field; opening up the licensure pathway to other avenues would be beneficial.  It is necessary and part of the lifeline for the continued success of the industry.  

I applaud this effort by VALA to place qualified, proven individuals in administrator positions and address the personnel challenges that are affecting all service industries at this time, in Virginia, and the rest of the country.  Too many competent, experienced leaders are being passed-over for positions, many already perform, because of formal requirements that don't guarantee success.  This is a progressive change that can only help this difficult situation.

The subject of assisted living administrators is close to my heart because both of my grandmother's currently reside in nursing homes and are taken care of by the staff of those facilities. There have been a few instances where my family questioned the leadership of the staff of one of my grandmother's facility. A movement towards requiring stricter trainings  is in the positive for me. Elderly citizens living in facilities are some of the most taken advantage of and least cared for throughout the country. The 80-hour training course would help ease the worry that some family members might have about those working with their elderly and/or sick family members. My grandmother has dementia and the enhanced training and continuing education given to both AITS and administrators would aid those working with patients like my grandmother who are mentally impaired. 

The Virginia Assisted Living Association (VALA) represents licensed assisted living communities from throughout Virginia of varying organizational structures and resident capacities. We thank the Board of Long-Term Care Administrators (Board) and the Regulatory Advisory Panel (RAP) for considering areas of improvement to the current regulations that will eliminate some of the barriers in the recruitment, licensure, and retention of licensed assisted living facility administrators.

In consultation with many assisted living providers throughout the Commonwealth, having an alternative pathway to licensure that includes licensure based on experience without a requirement to have completed hours at a college or university is crucial to having an expanded pool of candidates. Being able to train passionate staff members from a variety of departments within a senior living community helps to provide continuity of care, enhanced work ethics, and encouragement for providing career pathways that did not previously exist. The creation of the experience pathway to licensure also helps to eliminate the unintentional discrimination of AIT candidates based on income status, since many individuals were unable to go to college due to financial restrictions.

In addition to the alternative pathway to licensure, we have heard many positive comments about the inclusion of continuing education credits for registered preceptors overseeing an Administrator-In-Training. We are optimistic that the inclusion of the CEU opportunity will encourage more qualified, licensed administrators to become a licensed preceptor.

With the increasing number of elderly citizens needing long-term care services and the high number of retirements of administrators as a direct result of the COVID-19 pandemic, the long-term care communities need more opportunities to recruit, to train, and to license administrators. With these considerations in mind, we support the Board of Long-Term Care Administrators’ recommendations of amendments to the Regulations Governing the Practice of Assisted Living Facility Administrators.  

Again, we thank you for your considerations to improving the current AIT regulatory process by expanding the eligibility criteria to allow for more individuals to become administrators-in-training. Please let us know if you have any questions regarding these comments.  

This amendment to include experience as a qualification for the AIT program is vital to the success of many individuals in this field. The experience of working in an Assisted Living Facility as part of the management team over the years will give you more training to be a successful Administrator than any college course. I've been blessed in my career to have worked with some of the best in the field. The wealth of knowledge and experience I've gained by being with them and the DSS State inspectors is invaluable. I thank the Board of Long-Term Care Administrators and the Regulatory Advisory Panel for their consideration of these amendments.