Response to House Bill 1978 – Concerns and Recommendations from a Senior Housing Professional Dear Delegate, I am writing to share my perspective on House Bill 1978 as a Registered Nurse and Licensed Long-Term Care Administrator with 17 years of experience in the senior housing industry. While I understand and appreciate the intent behind making the process of establishing small licensed homes more accessible, I have concerns about the potential consequences of loosening regulatory requirements without ensuring appropriate oversight. One of the most significant issues with the current system is the complexity of obtaining licensure for a small residential home in Virginia. While I believe some streamlining could benefit prospective providers, it is also essential that a well-defined process remains in place to ensure that only qualified individuals operate these facilities. If regulations are significantly relaxed, there is a risk of an influx of new homes opening without the proper staffing, training, and safeguards in place—potentially compromising the safety and well-being of vulnerable residents. That said, I also recognize the financial and operational challenges that smaller facilities face compared to larger communities. Currently, small homes, such as my own 8-bed facility, are subject to many of the same regulations as large-scale assisted living communities, despite having significantly fewer resources. I strongly advocate for regulatory adjustments that consider occupancy size while maintaining a high standard of care. For example, compliance measures should be proportionate to facility size, allowing smaller providers to meet essential standards without undue financial burden. Another critical concern is the growing demand for senior housing. With an increasing number of aging individuals in need of care, small residential homes play a vital role in providing safe and personalized environments for seniors. However, maintaining quality should not come at the expense of accessibility. Striking the right balance between regulatory oversight and operational feasibility is crucial in ensuring that these facilities remain a viable option for seniors and their families. I urge lawmakers to consider a tiered regulatory framework that ensures safety and accountability while acknowledging the financial and operational differences between large and small senior housing providers. I welcome the opportunity to further discuss this issue and provide insight into how we can create a more effective and sustainable model for small licensed homes in Virginia. Thank you for your time and consideration. I appreciate your commitment to improving senior housing options in our state and look forward to seeing how this legislation develops. Sincerely, Shauna Toussaint MSN, RN Liscensed Long Term Care Administrator CEO of Pivotal Senior Services CEO of Pivotal Assisted Living shauna@pivotalseniorservices.com

I have been a Licensed Administrator and a Nurse In Assisted Living since mid 2000. Keeping the older people safe and secured is a BIG JOB and 24 hour responsibilities. You need to have the talent, education and experience . I truly believe that we need to have a HIGHER Standards in VA to protect our seniors in VA. Assisted Living nowadays is similar to a NURSING HOME. We take care of People that needs a lot of medical needs. DONT ALLOWED LOWER STANDARDS. WE NEED AN OPERATOR WITH ADVANCE DEGREE and TRAINING. ASSISTED LIVING IS LIKE A NURSING HOME NOW

I have been a Licensed Administrator and a Nurse In Assisted Living since mid 2000. Keeping the older people safe and secured is a BIG JOB and 24 hour responsibilities. You need to have the talent, education and experience . I truly believe that we need to have a HIGHER Standards in VA to protect our seniors in VA. Assisted Living nowadays is similar to a NURSING HOME. We take care of People that needs a lot of medical needs. DONT ALLOWED LOWER STANDARDS. WE NEED AN OPERATOR WITH ADVANCE DEGREE and TRAINING. ASSISTED LIVING IS LIKE A NURSING HOME NOW

I have been in this business since 1980 and we have worked hard and deligently on taking care of seniors, mental health people, on a 24 hr basis and I should NOT be asked to take a test to become an Licensed Administrator when I have did this job for over 30 years. The Administrators today cannot operate the facility because they don’t have patience and it’s to stressful so they quit!!! I want to be Grand-fathered in as an Administrator anyone who has been in this business since 1980 should be given a pass to operate without being required to go to school to be a license Administrator you will never find dedicated people like me again and who are willing to hang in there and keep taking care of the people for they have no family members or any where else to go and we become like family to them. Taking us away will only hurt the facility and the residents who have become to look at the facility as home and love the management. They should be given a choice and not the state making that for them. If you mandate 45 years of dedication to be taken away some Residents could be harmed by taking away the very people who have cared for them and who they respect and love. Also state regulations should be for Assisted Living not Nursing Home for most of them are privately owned by big corporations who never see the Residents and it’s only a money game with them . We should be credited for our love and dedication because no one could stay in business by the rate the State pays to take care of people 24 hours seven days per week, but we have hung in there and managed because we care and these people had no where else to go. It’s really bad now because you cannot find dedicated staff to work in no department but especially Management and Nursing. So i ask you with a heavy heart DONOT MANDATE anyone in business since 1980 to go to College and earn a degree to become a License State Administrator for and Assisted Living in order to keep there business and continue to take care of the Residents that are in their facility and it’s there home. We / me should be grand-fathered in and continue to operate And find some great dependable staff that have some education and experience in working with the Elderly. This business is the only business left for people to feel like they are at home because it’s affordable Nursing Homes are extremely expensive and a lot of low income people do not qualify or sex offenders so they become homeless or a person of the streets. We must do better when we are thinking about people And their lives. Yes we are accountable but you Put people in harms way when we don’t allow people to live their lives to the best of their ability. So again if you have been in business like I have over 45 years I DONOT need to be a license Administrator please Consider this please.

Support HB 1978

In support of passing this bill. VA is in great need of evaluating (1) the state requirements to become an administrator (2) the over-regulation of ALFs in the state and the (3) lack of distinction between small ALF communities and large ones. They are all evaluated by the same list of hundreds of standards that do not make working sense. (4) Inspection regulations hold facilities to standards far past excellent care of the residents and a good loving environment for our elders - read all 200+ pages of the regulations from VDSS. Further - The NAB exam does not evaluate the tester's knowledge of Virginia regulations, as it tests an individual’s knowledge of nationally accepted practices in long-term and post-acute healthcare industries, which sometimes conflict with Virginia’s regulations for assisted living facilities. The pass rate of the exam is less that 50% and the supply and demand for ALFs must be revaluated. There is a significant shortage of licensed preceptors available to train AITs and there have been recent barriers to entry imposed by even more regulations around the rules of being a preceptor in VA. It is very clear there is a shortage of administrators in VA for this industry but there is no shortage of facilities. This is the first time in US history there is more aging population than young people. People are moving out of state to work in this industry because it is easier to carve out a career path in other states.

The study for licensure for Assisted Living is greatly needed! I sat for my exam in October of 2020. Prior to sitting for the exam I had built a 15 year career at that point in skilled nursing and nursing homes. I had completed the AIT track after completing my Bachelor's in Healthcare Management. During the time leading up to sitting for the exam I was very suprised to find out that the exam did not really center on Assisted Living, but senior living in general coupling our sector in with skilled nursing. With the experience I had gained in Skilled Nursing and Nursing homes I was able to pass with ease and was fortunate to have had that foundation. I currently have been a preceptor for a few years now attempting to help the next generation of healthcare executives, because we can not wait another 15 years for a new generation of executives. I find it frustrating as a preceptor that I am having to help teach knowledge on policy, procedures, and regulations that lay outside the Assisted Living sector of healthcare to those who are the next to sit for the exam. Our level of care is different, it is not cookie cutter, should we not have a professional licensure track that mirrors the educational and skill needs of our specific industry?

Hello , my name is TaKeia Davidson . I want to take the time to advocate for the AIt students . I had an extremely hard time finding a preceptor In my area . I searched and was in contact with different preceptors for years. I had experienced in NC . I feel as if a solution would be to have more support through the process, schools work force development centers , help paying for administrator in training programs. Most people have never heard of the program. Market the program in colleges and work force development opportunities so that the demand in Communities will be met . Thank you so much for your time .

From July 2014 through July 2016, I was a Sales and Marketing Director for an Assisted Living Community in Danville VA. While in that position, I learned a lot about Assisted Living and the VA Regulations. When my Administrator transferred to another community, it was recommended that I go through the AIT program to become licensed as an assisted living administrator to take over my community. I had been a professional real estate agent for 15 years prior to senior living, but did not have any education higher than a high school diploma other than the many real estate coursed that I had taken. I was deemed "unqualified" to apply to participate in the administrator-in-training program due to not enough education. A couple months later, I was offered a position in a NC community. In NC, I could serve as the Administrator with another administrators license in the community. I worked full time for 2 years while taking classes at the community college year round. I tried to take classes that I felt would help me as an administrator, but many I took to acquire the highest number of credits needed to apply quickly. It was such a waste of my time and money to have to complete courses simply to have the required number to apply. Then went through the AIT program. The five years that I worked in NC, I could have been a VA administrator had the regulations for VA not been so excessive. In 2021, I finally made it back to VA, took the administrators exam and became a VA Long Term Care Administrator. I have been working for Commonwealth Senior Living since that time. If you do any continuing Education for AL, you know that soon the state is going to be bombarded with baby boomers who will require senior living. How are we going to meet that need if the licensure process is so difficult and their is a shortage of Administrators. I urge you to please pass HB1978 so that the JCHC can conduct the study on the licensure process for assisted living facility administrators. In conducting the study, the JCHC will be able to determine any potential barriers to licensure as an assisted living facility administrator and make recommendations on policies to increase the accessibility of licensure. We will all benefit from this study whether we are seeking to be licensed administrator or those in need of senior living in the future.

Our industry needs dedicated men and women with a heart for service who are willing to commit to the time and stress of the job. Barriers currently in place prohibit those who may have the life experience to operate communities and provide for excellence in the care of residents and the mentoring of others on the team. I would ask the current requirements be reevaluated such that we do not eliminate those who may contribute to our industry and society.

Opportunities:  Virginia can serve as a leader in recruiting, training, and retaining highly qualified assisted living administrators by reducing barriers to licensure and by expanding pathways to licensure to fulfill workforce needs.  By expanding credentialing options, Virginia strengthens its career options and workforce expansion opportunities by developing and maintaining a continual pipeline of talent  Fulfilling the goal to remove barriers to licensure could create viable pathways to licensure allowing ALFA candidates to decide which options works best for them and their career goals.  HB1978 supports a thorough analysis of any barriers to licensure and creates an opportunity to make recommendations on policies to increase the accessibility of licensure. Support HB 1978.

As many of know, there is a shortage of healthcare workers. Most times we only think of clinical team members, but there is also a shortage in healthcare administrations. There are many reasons why we have the shortage, but the one that we can reduce is the ability of administrators to be qualified to practice in a community. We are requesting that their be data collected to look at the regulations set out by DSS and other state codes to see if anything can be revised to support more people to become eligible to be administrators. Caring for residents is something that is not going away and we need leaders that help manage the day to day. We would love a round table or opportunities to share more feedback on the barriers that prevent people from joining this workforce.

I support HB1978! The state of Virginia is one of the difficult state to operate assisted living. Having worked in multiple states for other companies, I find VA to be one of the most challenging states to operated. The over regulatory environment makes it impossible for provide quality care and services. The requirement for adminsitrator licensure is over burdensome in the following ways: * The regulatory requirement for a preceptor is burdensome. Hours requires and lack of qualified preceptors makes it impossible to get folks licensed. * The testing is extremely difficult and the pass rate in the state is dismal. * The test is a standardize test that doesn't have anything to do with VA and assisted living. The state is nursing home test. * Significant amount of AIT hours in addition to working a full-time job, balancing school, and/or balancing home life is a real barrier for younger people who want to begin a career in senior living in VA.

As someone who is responsible for 25 assisted living communities in VA, supporting thousands of seniors and employing thousands of VA residents, I strongly encourage passage of this bill. Thank you, Earl Parker

Comments Document

The Virginia Assisted Living Association (VALA) represents nearly 200 licensed assisted living communities (ALF) throughout the Commonwealth of Virginia of varying capacities and operational structures. We receive many calls for assistance in understanding the process of becoming a licensed assisted living facility administrator (ALFA) from individuals currently working in Virginia as well as individuals wanting to move to Virginia. We often hear the desperation and disappointment in their voices when they review the prerequisites to even enter the required administrator-in-training (AIT) program and the requirements of participating in the AIT program such as the requirement to complete 320-640 hours of precepted training and a national examination. We are often told Virginia has some of the most restrictive requirements resulting in loss opportunities for recruitment and a significant shortage of licensed administrators to fill the industry’s need. A review of other states and their respective AIT programs resulted in a competitive average training requirement of 180 hours, the allowance of knowledge exams based on state regulations, and varying eligibility requirements to enter their respective AIT program. Virginia’s requirements create barriers to entry for becoming a licensed administrator, barriers to operation for assisted living communities, and a reduction in long-term care housing options for seniors as assisted living communities are required to have a licensed administrator. VALA often hears from assisted living providers that are struggling to recruit administrators due to the shortage. These calls expressing concerns about administrator vacancies were exacerbated throughout the COVID-19 pandemic. During the COVID-19 pandemic, many administrators were overworked and burned out resulting in many leaving the profession. Virginia has a deficit of available licensed administrators to meet the needs of the industry, as some individuals have retained their license but are not actively practicing in the industry. According to the VA Healthcare Workforce Data Center (HWDC), the percentage of licensed ALFAS working in an ALF as their primary location has been steadily decreasing from 84% in 2013 to 64% in 2024. According to HWDC, the percentage of ALFA licenses not renewed each year is generally greater than the percentage of new licenses highlighting the labor shortage of ALFAs. HWDC also reports that 30% of the currently licensed administrators plan to retire within 10 years and 21% plan to either leave the profession, leave Virginia, decrease their patient care hours, or decrease the teaching hours within 2 years. Virginia can serve as a leader in recruiting, training, and retaining highly qualified assisted living administrators by reducing barriers to licensure and by expanding pathways to licensure to fulfill workforce needs. By expanding credentialing options, Virginia strengthens its career options and workforce expansion opportunities by developing and maintaining a continual pipeline of talent. HB1978 supports a thorough analysis of any barriers to licensure and creates an opportunity to make recommendations on policies to increase the accessibility of licensure. We encourage and ask you to support HB1978.

I strongly support HB 1978. It has been very difficult for us to find a preceptor able to train an AIT.

It is imperative HB 1978 is approved. It is necessary to ensure the leadership solvency of assisted living communities for years to come. It is very difficult to find and train licensed administrators. This study would allow for a thorough review of barriers and opportunities to improve the licensure process.

It is imperative HB 1978 is approved. It is necessary to ensure the leadership solvency of assisted living communities for years to come. It is very difficult to find and train licensed administrators. This study would allow for a thorough review of barriers and opportunities to improve the licensure process.

Requirements for an AIT are restricting many from becoming licensed. The educational requirements are restrictive, as there are many candidates who would be exceptional but do not have the college credits, but do have life experience. Field experience should equal college credits. Second, the number of hours required is excessive for a person with field experience, especially as they have most likely already performed many of the duties suggested in the training. The extensive hours should only be required for someone with education but no experience. Third, the reason preceptors are difficult to find is that this is restricted to two people at a time. As a consultant, I would be a preceptor full-time and help many AITs get trained, since I have 30 years of experience, but with the limit of only two AIT at a time I would not be able to make enough money to do this. Since only 8 hours a week is required to spend with each person, a preceptor should be able to have at least 5 AIT at a time. Also, the rule should be removed that a preceptor must have served as an Administrator within the past 2 years. As a consultant, I work IN and FOR communities but not always in the role of Administrator. A preceptor who is a licensed administrator, and has served as an Administrator for a total of over 5 years OR in the past 2 years should be allowed. Thank you for the opportunity to express my views.

Good evening, As a lifelong human services professional seeking credentials to start my encore career as an assisted living facility administrator (ALFA) in Virginia, my efforts are greatly impacted by the number of obstacles and challenges that I must overcome to do so. I am a graduate student in the Master’s of Gerontology program at VCU, slated to graduate in December 2025. However, I already possess an M. Ed in Leadership, Policy, and Organizational Management, a Post-Baccalaureate Certificate in Disability Leadership, and my work experience includes serving as a training coordinator for a healthcare company, a social worker for nearly 20 years in the City of Richmond, and a stint managing a public guardianship program. I also serve on several boards and committees that address and focus on senior related issues and concerns, such as the Aging and Disability Advisory Board (ADAB) for the City of Richmond and the Chesterfield Council on Aging (CAA). Yet, according to the guidelines for ALFA licensure in Virginia, I still need 320-640 hours of an administrator-in-training (AIT) program, which will have to be done along with working my full-time job that I need to take care of my family. This means I will have to craft a schedule that my current employer will hopefully support while trying to figure out how to manage 70-hour weeks of work and AIT responsibilities along with completing the remaining academic coursework. I have looked at ALFA licensing requirements for other states and considered relocation just because I would be able to achieve my goal much more quickly and reasonably, in a state such as North Carolina, which offers a state-based exam and will recognize and would acknowledge what I currently possess academically and professionally. Virginia has always been my home, and it is my desire to have it remain so, to utilize my time and talent for the benefit of the residents of the state I love. I respectfully ask your support for HB 1978 to ensure that others seeking to become ALFAs in Virginia have pathways to do so that fit their individual goals and circumstances. Thank you, Glynis Boyd Hughes