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]
Previous Comment     Next Comment     Back to List of Comments
4/2/24  11:32 am
Commenter: Andrea Rehm de Cocito

In support of this petition
 

I write to you not just as the owner and administrator of three small assisted living homes but as someone who has nurtured and grown this vital service from a single house in 2004 to the thriving community it is today. This growth was not merely in capacity but in the depth of understanding and commitment to the unique needs of our residents. My concerns regarding the Administrator in Training (AIT) Program in Virginia stem from a place of deep industry knowledge and a firsthand understanding of the challenges faced by small providers.

The regulatory framework that restricts facilities with fewer than 20 beds from becoming training facilities for Administrators in Training unfairly disadvantages smaller providers like us. This regulation disregards the operational nuances and the tailored care that small assisted living homes provide. Our model is built on close-knit community care, something that cannot be replicated in larger facilities, nor can it be taught through their training programs.

The requirement for offsite training in larger settings not only overlooks the essential skills necessary for managing smaller facilities but also imposes significant financial and logistical burdens on us. Furthermore, this law indirectly discriminates against minority and women-owned businesses, a demographic that significantly represents small assisted living facility owners. The implications of this are twofold: it hinders our operational effectiveness and diminishes the diversity that is crucial to the fabric of our industry.

In solidarity with Sandy Rosenblatt of Avalon House and other small providers, I advocate for the amendment of 18VAC95-30-170-B-4. This amendment would allow providers owning multiple licensed ALFs within a reasonable travel distance, with a combined total capacity of at least 20 residents, to qualify as eligible training facilities. Such a change is essential for providing a training ground that reflects the realities of small facility management, ultimately benefiting the broader assisted living community.

From starting with a single home in 2004 to reaching where we are today, my journey reflects a commitment to providing personalized, compassionate care. This proposed amendment aligns with our collective goal of fostering a diverse, inclusive, and equitable assisted living landscape in Virginia. Changing these requirements will give small assisted livings the chance to thrive, removing unnecessary burdens and leveling the playing field for small businesses. Your support for this amendment will not only aid in rectifying the current disparity but also ensure that the training of future administrators is comprehensive, inclusive, and reflective of the varied needs of our communities. 

Your support for this amendment will not only aid in rectifying the current disparity but also ensure that the training of future administrators is comprehensive, inclusive, and reflective of the varied needs of our communities.

Thank you for considering our appeal. Together, we can work towards a regulatory framework that truly supports the growth and sustainability of all assisted living facilities, regardless of their size.

Sincerely,

Andrea Rehm de Cocito

CommentID: 222475