As the current regulation is written, it excludes ALL small group home providers in the state from serving as AIT training facilities. That being the case, the regulation not only favors large facilities, but it also places all small group homes in the state at an unfair disadvantage. 

Not only can it be difficult to find and hire an Administrator for any provider, but it has been our experience that many of the larger facilities that have been allowed to create and implement an AIT training program, are unwilling to take on anyone in their program that is not their own employee for a variety of reasons. Where does that leave the small providers in the state? The small providers are left in a place of not being able to train their employees to become Administrators, as well as not being able to get them trained elsewhere. How is that sustainable. Quite frankly, as it is written, the current regulation discriminates against small group home providers. 

Around 25% of facilities in the state of Virginia are small group homes. Of those, there is a good percentage of those facilities that have more than one home and when all of their homes are combined, they total 20 beds or more. 

Small group homes are becoming more prevalent and there seems to be a higher demand for them as our loved ones are aging. I suspect we will see that 25% rise over the next few years. 

We request the regulation is changed in order to be inclusive not only to the large providers, but the small ones as well.