We support VDH's efforts to strengthen accountability and clarify how enforcement actions may be applied when resident safety is compromised.  However, the current proposal does not go far enough to address the severity and persistence of violations occurring across Virginia's long-term care system.

Virginia's nursing home residents continue to experience preventable harm due to chronic understaffing, inadequate behavioral health support, and repeated failures to meet basic regulatory standards.  Many of the facilities with the most serious deficiencies are owned by large, multi-state corporations whose business practices prioritize profit over care.  Without clear, enforceable sanction criteria--and without consequences that meaningfully deter repeat violations--these patterns will continue.

The Advocate Voice Virginia urges VDH to adopt stronger, more explicit sanction triggers, including:

1. Mandatory enforcement actions when facilities repeatedly fail to correct serious deficiencies affecting resident health and safety.
2. Clear criteria for license suspension or revocation when harm is ongoing or systemic
3. Sanctions tied directly to staffing failures, including insufficient CNA coverage, lack of RN oversight, and failure to provide behavioral-health services required by care plans
4. Enhanced penalties for corporate repeat offenders whose facilities demonstrate patterns of neglect across multiple locations
5. Public transparency requirements so families can easily identify facilities under sanction, including the nature of violations and the status of corrective actions

We also encourage VDH to incorporate resident-centered measures into its sanction framework.  Families and residents consistently report issues that do not always appear in inspection data--such as untreated behavioral symptoms, prolonged isolation, lack of meaningful engagement, less than adequate meals that fail to meet nutritional needs, and unsafe living conditions.  These experiences should inform enforcement decisions, especially when they reflect systemic failures.

Families are counting on VDH to develop a stronger, more effective sanction system that protects residents, promotes accountability, and ensures that facilities failing to meet their obligations face meaningful consequences.  Virgina's nursing home residents deserve a regulatory framework that prioritizes their dignity, safety, and well-being above all else.