The Association of Minority Owned ALF’s is asking for a thirty days extension on the comment period. We are asking that the Department of Social Services do a small business impact study. If the department had truly done a study, they would have concluded that the regulation put in place in 2007 crippled small African-American ALF’s and that anymore regulations without funding would force our businesses to operate in non-compliance or create a business hardship that causes us to have to shut our doors. The JLarc2006. Study stated that the rate is well below market price and that the limited revenue of these facilities will continue to constrain their ability to comply with new regulations.

Virginia has seen a decrease in ALF’s bed still more beds are being lost because of regulations without monetary funding.

We lost an average of 853 beds. 8 facilities closed since May 2015 with several pending.We know that if DSS had truly done an impact study they would know the difficulties ALF’s were having complying with the shortage of medication aids and how they have become a force to reckon with because they will not work for small ALF’s who cannot Pay $14 to $20 dollars.The auxiliary grant facilities are receiving $43.00 a day to take care of resident members. Medication aides are coming in at no less than $13 an hour at 16 hours we are putting out  $208.00 a day.

We are now competing with Hospitals, Large Private Paid Facilities, The Jails and Prison who can pay $20 dollars for medication because they are less costly than nurses.

We are asking that an impact Study be done so that no more burdensome regulation need to be pushed onto residential-only Alf’s without the increases that were called for by JLARC  in 2006.

Key Recommendations/Findings That Have Not Been Fully Implemented

AG monthly rate should be increased (1988, 1991, 1998, 2000, 2000, 2006, 2007)

• AG rate increased and linked to services provided (based upon determined level of care or SMI diagnosis) (1988, 1991, 1998, 2000)
• The personal allowance for AG recipients should be increased/evaluated (1991,1998)

We are asking that because we are a social model that any medical regulations should be required to be paid by DMAS and not to come out of the business owner pockets such as the regulations for healthcare oversites, dieticians, and Uai training and ISP training. We are not against regulations we are against creating regulations with out monetary resources to back up their endeavors.

We are asking that for residential only be exempt from increase in training and that for direct care it is to remain the same.

We are asking that residential-only facilities  med tech take the 68-hour training and annual four-hour training without having to be state license so that we are not competing with the larger organizations.

We are aware that Virginia assisted living facilities are having difficulty supplying a need to the low-income disabled individuals because in 2016 and 2017 Department of Human Resources made an amendment (line item K 304… in the budget for $250,000 a year to ensure that Birmingham Green Assisted Living facility can continued to provide residential services to low-income disabled individuals (Senate bill 30).

We are asking that the General Assembly please make an amendment so that all auxiliary grant facilities receive an increase so that we ALL may have the opportunity to provide continuous services to our low-income disabled and not just a select few.

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