As an assisted living provider, we are deeply committed to creating a strong, compassionate, and competent leadership pipeline to serve our residents and their families with excellence. Our team applauds the efforts of the Virginia Assisted Living Association (VALA) for their leadership in advocating for reforms to Virginia’s current regulations for Assisted Living Facility Administrators.

We support VALA’s recommendations to the Virginia Board of Long-Term Care Administrators and extend our gratitude to Governor Youngkin and the Board for acknowledging that many existing regulations create barriers for talented, qualified individuals to enter and remain in the assisted living workforce. 

Our organization is particularly concerned with the testing challenges faced by Administrators-in-Training (AITs) in Virginia. The current national exam often fails to reflect the specific regulatory knowledge required to operate in Virginia. This misalignment has resulted in unacceptably high failure rates, which not only discourages capable candidates but also delays or derails their entry into the workforce at a time when administrators are desperately needed.

We echo VALA’s recommendation to allow for a Virginia-specific exam option, alongside the national exam, so that AITs may choose the testing path that aligns with their career goals—whether they seek portability or a dedicated career in Virginia. This flexibility is not only practical, but fair, and would immediately increase licensure success rates and administrator retention in-state.

We support proposed changes that would:

• Reduce AIT training hours to align with national averages, making the pathway to licensure more accessible.

• Expand educational equivalency to include individuals with doctoral degrees and substantial experience, even those without managerial titles, broadening access to qualified candidates.

• Allow smaller assisted living communities and contracted administrators to participate in AIT training and preceptorships, especially important for rural and underserved areas.

• Create a pathway for non-traditional but experienced healthcare workers to become administrators, strengthening the diversity and depth of the leadership pipeline.

In line with VALA’s feedback, we also support changes to the following:

• 18VAC95-30-100-A-1 – Reduce required training hours to align with national averages:

• 18VAC95-30-100-A-1-e/f/h – Expand education eligibility to include doctoral and experienced healthcare professionals without formal management roles.

• 18VAC95-30-10-B – Broaden exam definitions to allow flexibility for national or state-based examinations.

• 18VAC95-30-110 – Allow applicants to choose between the national exam or a new Virginia-specific exam.

• 18VAC95-30-120-B-4 – Remove the word "national" to broaden examination recognition for endorsements.

• 18VAC95-30-140-A-2 – Allow AITs to secure a preceptor within 60 days of program approval rather than as a prerequisite.

• 18VAC95-30-170-B-4 – Permit smaller ALFs (fewer than 20 residents) to serve as training facilities.

• 18VAC95-30-180-B-2 – Allow contracted or consulting administrators to serve as preceptors.

• 18VAC95-30-180-C – Allow preceptors to supervise up to three trainees at a time.

• 18VAC95-30-130-C – Allow the Board to retain incomplete application materials for up to two years to accommodate delays in obtaining documentation.

• 18VAC95-30-91 – Reduce continuing education hours for reactivation of an inactive license to 30 hours, including 2 hours of regulatory updates.

• 18VAC95-30-40 – Support the creation of the "Inactive License" category but recommend lowering the inactive license fee to less than $150 and aligning late fees with similar roles.

• 18VAC95-30-70-C-2 – Support the removal of the requirement for signatures on continuing education certificates.

• 18VAC95-30-80-A – Support replacing "shall" with "may" to allow more flexibility for late renewals.

• 18VAC95-30-200 – Support removing the requirement to obtain a new preceptor within 60 days if the program is interrupted.

We urge the Board of Long-Term Care Administrators to adopt these proposed amendments and continue working closely with advocates like VALA and providers such as Cardinal Senior Living to ensure Virginia remains competitive in recruiting, training, and retaining high-quality assisted living administrators.

With thoughtful, balanced regulatory reform, we can ensure a better future for both the professionals who serve in our communities and the residents who depend on them.

Respectfully submitted,
Cardinal Senior Living