We thank the Virginia Board of Nursing (BON) for considering actions to alleviate unnecessary burdens on Virginia’s caregiving workforce and to open additional pathways of training for those caregiving individuals employed by licensed assisted living facilities. 

We appreciated the Commonwealth creating a waiver during the early period of the COVID-19 pandemic that removed the restriction on training locations for the clinical hours training of certified nursing assistants (CNAs) to be done outside of a “geriatric long-term care facility,” which included having the hours completed within an ALF. This waiver allowed for assisted living communities to train additional CNAs to help with providing continued resident care with permanent staff members. Having spoken with numerous assisted living providers and with staff from several of Virginia’s regulatory agencies, we support the BON making this waiver a permanent option that would allow assisted living facilities to be included in the allowable training facilities for CNAs.