Thank you to VDH for providing this opportunity for public comment in an effort to strengthen much needed SNF oversight. I urge VDH to look beyond individual facilities and examine the corporate structures and patterns behind them. Hill Valley Healthcare, a newer company, is an important example of the concerning patterns. 

Hill Valley places strong emphasis on census, yet staffing and resources do not keep pace with the needs and acuity of the residents who are being admitted. Residents are not occupied beds; each admission requires person centered care which means additional nursing care, medications, treatments, meals, bathing, EVS, activities and supervision. This company aggressively pursues census without equally investing in the resources necessary to care for that census. 

The concerns extend far beyond nursing care. EVS staffing cuts impact cleanliness, basic supplies are limited, residents experience horrible meals and minimal breakfast meats, no consistency with menus  and run out of food or don’t order enough. Dining rooms have been closed and residents must eat alone in their rooms. These cuts directly impact resident dignity, health and quality of life. 

Hill Valley emphasizes employee satisfaction with surveys, and while employee satisfaction is important resident and family satisfaction should receive the same attention, if not ore. Are call bells answered? Are showers provided? Are rooms cleans? Are there enough towels? Is your food good? Is it appealing? Do you get bough? Can resident’s eat together? Is there enough staff to meet your needs? 

VDH already possesses staffing, turnover, survey, complaints and quality data. They need to now take the opportunity to connect the dots. When similar concerns are reported repeatedly across facilities under common ownership VDH should not treat each building as an isolated problem. It should examine corporate staffing models, budgets, purchasing restrictions, administrative turnover, dietary and EVS resources, supply availability, resident outcomes and the actual authority local administrators and DONs actually ah e to address problems. 

If the pattern is corporate then the accountability must be corporate. 

Repeated citations and plans of correction at individual facilities will accomplish very little if the decisions creating those conditions are being made somewhere above the facility administrator. 

Virginia should follow the problems to wherever the decisions are being made and hold that level of leadership responsible. Corporate structure at Hill Valley considers itself “consultants” and refuses to acknowledge or accept  ownership of what they force their communities to do which negatively impacts care. 

Residents are not census. They are people. And any company that has the resources to fill beds has an ethical responsibility to provide appropriate staffing, palatable food, supplies, cleanliness, and dignity necessary to properly care for the residents occupying those beds.