we wish to leave this as is with staff being able to sleep and getting up periodcally and checking on the resdident during the night .  we hAVE A CAPACITY OF 16 RESIDENTS  and have alarms on the bedroom doors the exit doors and check on our resiednts during the night and have alarms in their rooms also.so we are not in favor of staying awake while working .

Propose final regulations allow for the resident to be issued a personal signaling device (pendant) along with fixed unit as a second option to rounds.  This issuance and instruction noted on ISP in lieu of frequency of rounds on ISP.

Proposed final regulations allow for the resident to be issued a personal signaling device (pendant) along with a fixed unit as a second option to rounds.  This issuance and instruction noted on the ISP in lieu of frequency of rounds.

The proposed changes to this regulation add aspirin and antibiotic cream to the first aid kit.  Both of these items require a physician's order to use or administer.  These are useless items for an emergency in AL and do not need to be in the first aid kit.

In section A the new wording states "Each facility shall report  to the regional licensing office within 24 hours any major incident....."  This needs to have "or the next business day" added.  Most facilities do not have staff on the weekends to complete this and most licensing offices are not open on the weekend.

T

The JLARC Study bought out three points that I would like to discuss

1. It stated that the regulations that have put on assisted living facilities that work with the (AG) program are burdensome and that the cost for AG is unfair Market pricing

1. JLARC stated that Assisted living facilities that work with this program should be making at least 3750.00 a month

   We only mak 1219.00

    

2. JLARC stated that because of these regulations we will be looking at a crisis because bed will not be available because they are decreasing and with these regulations that are put into place without extra funding; many AG housing programs will be shut down or closed

3. JLARC stated that assisted living facilities that take the clients who need a little more assistance would also decline; especially that they are not receiving any funding for the extra hours of training, and extra staffing, and extra oversites

There fore; we are wondering why DSS is still trying to regulate without the necessary resources such as money to follow these regulations

We also notice an increase in unsupervised housing for clients with mental disabilities; and that they are allowing them to go into these facilities and as well as creating model programs that would allow clients to go into unregulated facilities; yet they bombard us with them;

1. We are not medical facilities and we should stop looking like mini-institutions with all the nurses and RN and dietician let them stay in the nursing care business

2. We are not big business and we are minority businesses and they are attacking our business where we are not able to stand and we cannot compete with unregulated facilities and facilities that make over 5,000.00 for their clients; we are room and board and we provide 24 hours of prompting, monitoring clients behavior, and making sure they get help from resources within the community. We are not paid or designed to be medical providers or miracle workers.

3. So, if you look at these new regulations don’t allow any regulation that strain residential or those who accept the AG program. Lets work together and see that we provide an awesome service but what good is the goody to notion but our clients out in the community without proper supervision and care; in shelters; in the street; because it looked like you working against us to eliminate us through your unmandated regulations

1. There is a regulation to increase the training hours- training hours for residential direct care workers are efficient for the things we need or what we do

   We are already in a hole all these regulations do is just bury us.

   And it is an impact to an already struggling industry; because on hands training is the best training for the residential training; we are not bathing clients, we are not turning them over we are not going to make more money for VCU dementia programs and give more money to some nurse sitting on the board who want to open a training school. WE are drained even a leech know how to get off a blood source knowing to take a little at time so the source can aleast survive.

The Auxiliary Grant guidance document indicates that a resident is no longer considered an Auxiliary Grant recipient when his residency ends in an Alf or AFC home. This occurs when a resident is absent from the facility or home 14 consecutive days, when they are discharged, has left the facility without plans of returning or Medical evidence indicates that they are not returning. When a person is discharged from the hospital to a nursing facility for rehab, the resident's level of care changes and because they are in a nursing facility their funding level has changed to Long Term Care. An Auxiliary Grant resident is unable to meet the requirements of a bedhold policy unless they are private pay. The local department of social services are not able to pay for holding a bed at a assisted living facility or adult foster care home. Also, according to Social Security Administration policy if a person goes to jail for an extended period of time they are not eligible to receive SSI; therefore, they are not eligible for the Auxiliary Grant as well.

22VAC40-73-325. Fall risk assessment.

A. For residents who meet the criteria for assisted living care, by the time the comprehensive ISP is completed, a fall risk assessment shall be conducted.

B. The fall risk assessment shall be reviewed and updated:when the condition of the resident changes to increase the resident’s fall risk.

1. At least annually;

2. When the condition of the resident changes; and

3. After a fall.

C. Should a resident fall, the facility must show documentation of an analysis of the circumstances of the fall and interventions that were initiated to prevent or reduce additional falls.

Can DCS or does a nurse have to complete the fall assessment and analysis/assessment of circumstances of the fall /interventions?

Medication administration training should not be required for administrators who do not directly supervise medication aides, and/or have a full time licensed Director of Nursing on staff.

Type

Recommended Changes to the Proposed Licensed Assisted Living Facilities Regulation Comprehensive Revision

22VAC40-73-30. Program of care.

There shall be a program of care that:

1. Meets the resident’s population's physical, mental, emotional, and psychosocial, and spiritualneeds;

2. Promotes the resident’s highest level of functioning

   2. 3. Provides protection, guidance and supervision;

   3. 4. Promotes a sense of security, self-worth and independence; and

   4.5. Promotes the resident's involvement with appropriate programs and community resources.based on the resident’s needs and interests.

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22VAC40-73-70. Incident reports.

A. Each facility shall report to the regional licensing office within 24 hours or next business day any major incident that has negatively affected or that threatens the life, health, safety or welfare of any resident.

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22VAC40-73-110. Staff general qualifications.

2. Be able to speak, read, understand and write in English as necessary to carry out their job responsibilities; and

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22VAC40-73-290. Work schedule and posting.

B. The facility shall develop and implement a procedure for posting the name of the current on-site person in charge, as provided for in this chapter, in a place in the facility that is conspicuous to the residents and the public.

The facility shall post a sign directing questions or concerns to a specific place in the facility.

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22VAC40-73-325. Fall risk assessment.

A. For residents who meet the criteria for assisted living care, by the time the comprehensive ISP is completed, a fall risk assessment shall be conducted.

B. The fall risk assessment shall be reviewed and updated:when the condition of the resident changes to increase the resident’s fall risk.

1. At least annually;

2. When the condition of the resident changes; and

3. After a fall.

C. Should a resident fall, the facility must show documentation of an analysis of the circumstances of the fall and interventions that were initiated to prevent or reduce additional falls.

_________________________

22VAC40-73-340. Psychosocial and behavioral history.

A. 1. If the prospective resident is referred by a state or private hospital, community services board, behavioral health authority, or long-term care facility, documentation of the individual’s psychosocial and behavioral functioning shall be acquired. provided prior to admission.

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22VAC40-73-430. Discharge of residents.

H. Discharge statement.

Exception: In the case of death or the resident being discharged to another level of care within a community, a discharge statement is not necessary.

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22VAC40-73-680. Administration of medications and related provisions.

Suggest combining these provision because they are so similar

E. Medical procedures or treatments ordered by a physician or other prescriber shall be provided according to his instructions.

K. The performance of all medical procedures and treatments ordered by a physician or other prescriber shall be documented and the documentation shall be retained in the resident's record.

_________________________

22VAC40-73-750. Resident rooms.

1. The resident shall be encouraged to furnish or decorate his room as space and safety considerations permit and in accordance with this chapter.

   Add: The facility is only responsible to ensure that the furniture is safe for resident use.

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22VAC40-73-760. Living room or multipurpose room.

A. Sitting rooms or recreation areas or both shall be equipped with:

1. Comfortable chairs (e.g., overstuffed, straight-backed, and rockers);

2. Tables;

3. Lamps;

4. Television (if not available in other areas of the facility);

5. Radio (if not available in other areas of the facility); and

6. Current newspaper, if not available in other areas of the facility

_________________________

22VAC40-73-860. General requirements

C. Before construction begins for resident living areas or contracts are awarded for any new construction, remodeling, or alterations, structural changes plans shall be submitted to the department for review.

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22VAC40-73-950. Emergency preparedness and response plan.

A. The facility shall develop a written emergency preparedness and response plan that shall address:

1. Documentation of initial contact and annual contact, with the local emergency coordinator to determine (i) local disaster risks, (ii) communitywide plans to address different disasters and emergency situations, and (iii) assistance, if any, that the local emergency management office will provide to the facility in an emergency.

C. The facility shall develop and implement an orientation and quarterly annual review on the emergency preparedness and response plan for all staff, residents, and volunteers, with emphasis placed on an individual’s respective responsibilities.  The orientation and review shall cover responsibilities for:

D. The facility shall review the emergency preparedness plan annually or more often as needed and make necessary revisions.  Such revisions shall be communicated to staff, residents, and volunteers and incorporated into the orientation and quarterly review for staff, residents, and volunteers.

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22VAC40-73-980. Emergency equipment and supplies.

2.Antibiotic cream or ointment packets;

17. 81 mg aspirin in single packets or small bottle; and needs to be eliminated because you need a physician order to administer

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22VAC40-73-990. Plan for resident emergencies and practice exercise.

B. At least once every six months annually all staff on each shift shall participate in an exercise in which the procedures for resident emergencies are practiced with all staff on duty. Documentation of each exercise shall be maintained in the facility for at least two years.

C. The plan for resident emergencies shall be readily available to all staff. And the facility shall ensure the staff is able to execute the emergency plan.

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22VAC40-73-1030. Staff training.

B. Commencing immediately upon employment and within four six months, direct care staff shall attend six hours of training in working with individuals who have a cognitive impairment, that meets the requirements of subsection C of this section.

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22VAC40-73-1140. Staff training.

B. Commencing immediately upon employment in the safe, secure environment and within four six months, direct care staff shall attend at least 10 hours of training in cognitive impairment that meets the requirements of subsection C of this section.

over this text and enter your comments here. You are limited to approximately 3000 words.

Nowhere in 22VAC 40-73-110, or the entire "Part III Personal" section did I find specific instructions on the requirements for ALF staff completing a UAI for private pay residents. In the old reg there was a statement that provided direction for ALF staff under Letter A, Number 1, letter a.

As a pre-requisite for an Individualized Service Plan training, ALF staff must be educated on the content and use of the Uniform Assessment Instrurment.

In 22VAC40-73-450 letter B., 2. it states: The plan shall reflect the resident's assessed needs and support the principles of individuality, personal dignity, freedom of choice, and home-like environment and shall include  other formal and informal supports that may participate in the delivery of services. Whenever possible, residents shall be given a choice of options regarding the type of delivery of services.

This certainly speaks to PERSON-CENTERED CARE which is paramount to meeting the many complex needs of our seniors, our loved ones and ourselves when we enter our senior years. Because the concept of PERSON-CENTERED CARE is not a well known fact amongst the staff of ALFs, perhaps it would be a good idea to include this as part of the above regulation. I know this is true because I am a trainer for the ISP class and when I ask if the class participants know about PERSON-CENTERED CARE, very few, if any are aware of the concept.