I would encourage OLC to consider a more collaborative approach to the survey and enforcement process. Accountability is necessary, but the ultimate goal should be sustained improvement in resident care.

We also have to acknowledge the environment in which nursing centers are being asked to operate. These centers provide 24-hour nursing and personal care, meals, housing, medications, therapy, activities, social services, infection prevention, regulatory compliance, and support for some of the most medically complex and vulnerable people in our communities. Yet reimbursement often does not reflect either the cost or the extraordinary expectations placed on that care. In some cases, the daily cost of an ordinary hotel room can rival what is available to a nursing center to provide an entire day of care and services.

Against that backdrop, significant penalties and restrictions do not affect an organization in isolation. They can reduce resources available for staffing, recruitment, retention, education, and other investments that directly support residents. The unintended consequence can be the opposite of what OLC is trying to accomplish.

Surveyors have an important opportunity not only to identify deficiencies, but to help providers understand where systems and processes are breaking down. Timely feedback, open dialogue, and a shared focus on root causes and sustainable corrective action can drive meaningful improvement.

Providers should be accountable. But accountability should exist within a regulatory system that recognizes the realities of providing 24/7 care and encourages transparency, collaboration, and continuous improvement. The goal we all share is safer, better care for Virginia's residents, and the regulatory process should help make that goal more achievable.