Wording should be very clear that facilities must make efforts to involve family members or legal representatives when the Individual Service Plan (ISP) is developed or reviewed.  Also recommend requiring the facility to notify the family members and/or legal representatives whenever the service plan is updated.  This will ensure residents, particularly those with dementia, are not signing what they do not understand.

There are three protections that uphold having affordable and residential housing for those person who suffer from a mental disability. The first is the Olmstead act that calls for the states to make a comprehensive plan that will create "less restrictive " housing. However in 2005 the state of Virginia incorporated some extensive and  costly regulations that made residential- setting housing look like mini institutions. The homelike environment was usurp by medication aides, dietitians,healthcare over sites and having nurses as administrator.The second, was the jlarc study that showed the cost of these regulations and how it would negatively impact the small business because we were not getting the pay t hat would allow for this increase of restrictive regulations. The jlarc study also stated that homes should be paid at a rate of four thousand a dollars inoder to maintain compliance. We are only paid one thousand one hundred and fifty. The third protection is Governor Odonnell Executive Order 14 . This order called for departments to view the impact of costly regulations on small business and intrusiveness. The Department of Social Service clearly disregarded this order. They had rap sessions that used not one idea of small businesses and ignored all pleads for more studies on developing regulations that met the need of the client but also their continuous need for affordable housing.

      There is a big problem with the standards. the fact that large, corperation owned, private pay homes has to fallow the same standards as the small, family owned homes which accecept auxilary grant or AG. this is unfair and unjust. these standards are to strick and intended for large medical base homes, not small homes intended to be more of a soical structure. A small residental home with a maximum occupacy of eight residents only recived $9,200 giving they have a full house and or reciving all funds from local dss. with these standards they are required to have a staff of dietician cna,rn, med techs. at $10 a hr with 720 hours in a 30 day month payroll is $7,200.  Providing 3 healthy meals with  snack for 30days to eight grown men, grocery can run around $2,000 a mortgage or rent of $1,200 utilites (lights,water,phone,etc.) around $1,500 not to include repair,maintence  and cleaning supplies, exterminator, offices supplies, or the big one TAXES. the list goes on and on. its hard for any one to operate a successful busniess, or even its to top prority providing quility care to the residents with such strick standards and so little funds.  Something has to be done about the Assisted Living standards in order for the smaller, local family owned, residental, public pay AG homes to survive.

Increase supervision or require periodic observation of medication aides (all shifts, all stations) to ensure all medications are administered according to the physician's or other prescriber's instructions and consistent with the Board of Nursing curriculum for registered medication aides.  I witnessed numerous medication errors over the years, and primarily by aides who did not take the time to read and fully understand the information for each medication as written in the MAR.  All LPNs and medication aides must be required to follow proper medication administration procedures such as not pre-pouring medications, preparing and administering only one resident's medicines at a time, remaining with the resident to ensure pills have been swallowed, and other important guidelines.  Require the Medication Management Plan to include methods to identify pharmacy dispensing errors, e.g. mix-ups of drugs with similar names.  Narrow the +/- one hour window to +/- thirty minutes for medications identified as time-critical by a physician or other prescriber.  

There needs to be stronger language addressing hydration and better recognition and training for thirst.  Some medications can cause excessive thirst, and dementia and ill residents are not always able to communicate their desperate need.

I would like to see the standards separated for Residental Care and Assisted living due to the level of care provided. Residental Care do not perform the same level of care and should not operate under the same standards. Assisted Living requires more skilled nursing care and is funded at a higher scale that Residental Care. We do not have the funds to provide these services such as 6months oversights, etc. We do not provide the same level of care so these standards need to revised for us. Please take our concerns into consideration.