To prevent the imposition of an unfair and discriminatory burden on small providers of memory care and assisted living as well as the clients they serve, 18VA95-30-170-B-4 must be amended allow administrators-in-training to be educated in smaller facilities. Eligible training facilities should include a provider with multiple locations within a 30-minute average one-way distance, collectively accommodating no fewer than 20 residents, as eligible training facilities for an ALF AIT program or internship. There are a number of important reasons to change this rule.

For two decades, Larmax has operated over nine homes, each housing eight residents, catering to individuals who thrive in a smaller, more intimate setting. Such smaller facilities offer a crucial alternative to larger ones. While some individuals may adapt well to the atmosphere of a 100-person facility, others require more personalized care and may feel overwhelmed in a crowded environment. Residents and their families often depend on the willingness of smaller homes to address complex needs associated with conditions like memory loss and Parkinson's disease, which disproportionately affect the elderly. Many of our residents transition to Larmax after experiencing inadequacies in larger facilities, where their needs couldn't be met without relocating to specialized units or hiring additional private caregivers. In a world already lacking in residential options for the elderly with escalating care requirements, small homes play a vital role. Mandating that all administrators undergo training exclusively in large facilities, which have an environment quite different from small homes, would likely severely limit elderly Virginians' access to such accommodations and would result in administrators not prepared to meet the unique, personalized environments of these homes.

Administrators of small homes have distinct training requirements compared to those in larger facilities. In a smaller setting, administrators are directly involved daily in care provision, engagement, medical management, staffing, and other essential tasks. Training focused on tasks irrelevant to small homes, such as running a large laundry operation, is wasteful; an understanding of basic laundry procedures suffices for managing the needs of eight residents. What small home administrators truly need is training in staffing dynamics, leadership responsibilities, family communication, disease management, behavior intervention, and utilization of community resources. Denying small homes the ability to provide tailored training for their administrators is both illogical from a business perspective and counterproductive to the Commonwealth of Virginia's goal of offering diverse and high-quality options for families as their loved ones age. All administrator candidates must pass the same licensing exam, ensuring a baseline of competency. Beyond that, akin to medical residencies which are tailored to specific specialties, administrator training should align with the unique demands of their chosen work environment.