Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Long-Term Care Administrators
 
chapter
Regulations Governing the Practice of Assisted Living Facility Administrators [18 VAC 95 ‑ 30]
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3/11/24  12:12 pm
Commenter: Sharon Woolery

The Current 18VAC95-30-170-B-4 Regulation Discriminates Against Small Providers
 

The current regulation discriminates against smaller providers that own multiple licensed assisted living facilities that total at least 20 residents when combined & are in close driving distance to one another. It is extremely unfair and favors large facilities that have 20 beds or more. There are a good percentage of small providers/companies in Virginia that have several homes. If they were allowed to combine the numbers of each individual facility they own, they would in fact have a total of 20 beds or more. However, as the current regulation is written, small providers that own multiple facilities, are not allowed to do that. They are left to figure it out on their own and face many roadblocks due to this. The large facilities have been a significant advantage over the small providers with how the current regulation is written. Why has this been allowed or okay to do?

Rather than allowing for a small provider's employees to do their training in an ALF AIT program or for an internship onsite, one must send them off site to a location which if they actually find a large facility program who is willing to train them, it is a significant distance from their home or work.  Not only do the small providers lose the employee while they are off training elsewhere, but it can also be quite costly for the small provider. 

Not only that, but it also denies the employee the opportunity to get onsite training that would be specific to the facility they are currently employed at. 

It has been our experience that many of the large providers who do have an AIT training program in place, have been very unwilling to take on anyone in the program who is not a current employee of theirs or intends on becoming an employee of theirs. They give a variety of reasons why they are unwilling to do so. Where does that leave the many small group homes in the state then? 

Due to the growing demand of small group homes in the state, I do not see how this will be sustainable if the current AIT regulation is not changed to include small group homes being afforded the opportunity to create an onsite AIT training program. 

CommentID: 222267