ALFA recently commented on proposed rules from the Veterans Administration on its Aid and Attendance benefit. ALFA members are honored to currently serve thousands of veterans and their spouses in our assisted and memory care communities. Those veterans who benefit from the VA A & A program have enriched lives through the opportunity to live in a social environment that provides the needed assistance with activities of daily living and enriched quality of care and quality of life.

ALFA applauds the VA for proposing these rules and agrees with most of the proposed changes. For example, we support the 36 month look back period, and the clarifying definition of net worth as income and assets. However, ALFA has suggestions for recommended changes to the draft rules as follows.

The definition of Activities of Daily Living (ADLs) proposed in the rule is excessively limiting by eliminating two frequent reasons seniors move into assisted or memory care communities: the inability to ambulate on their own, and inability to administer their own medications. ALFA recommends that the VA use the definition of basic Activities of Daily Living as found in the Medicare Benefits Policy Manual, Chapter 16 Section 110 as follows: “Custodial care serves to assist an individual in the activities of daily living, such as assistance in walking, getting in and out of bed, bathing, dressing, feeding, and using the toilet, preparation of special diets, and supervision of medication that usually can be self-administered.”

ALFA’s second comment requests that the regulation address the  needs of residents that choose to live in independent living communities, and have care and services provided by the community or a third party provider separately contracted for by the veteran.