By Birmingham Senior Advisor Care Team · October 30, 2026
Table A in rule 420-5-20-.04 sets a floor of two staff for up to 16 memory care residents on every shift, three for up to 24 residents on days, 36 on evenings and 48 overnight, and one more for each additional 8, 12 or 16 residents after that. It is a minimum, not a target, and the rule requires more staff whenever residents need it.
Why Alabama's memory care rule is unusual
Many states describe memory care staffing in general terms, such as sufficient staff to meet residents' needs. Alabama's specialty care assisted living rule does that too, but it also prints a table. Table A of rule 420-5-20-.04 lists the minimum number of staff who must be on duty for a given number of residents during each of three shifts: 7 AM to 3 PM, 3 PM to 11 PM, and 11 PM to 7 AM.
The rule is explicit that the table is a floor. Even when the minimum is met, the governing authority must add staff as needed to meet residents' care and safety needs around the clock, and any wing separated from the rest of the building by a lockable door needs its own dedicated staff.
How the table works
Every shift starts with two staff for 1 to 16 residents. The third staff member covers up to 24 residents on the day shift, 36 in the evening and 48 overnight. After that, the table adds one staff member for each additional 8 residents on days, 12 in the evening and 16 overnight, or any fraction of those numbers. So the day shift steps up at 17, 25, 33 and 41 residents; the evening shift at 17, 37, 49 and 61; the overnight shift at 17, 49, 65 and 81.
| Residents present | Minimum staff, 7 AM-3 PM | Minimum staff, 3-11 PM | Minimum staff, 11 PM-7 AM |
|---|---|---|---|
| 16 | 2 | 2 | 2 |
| 24 | 3 | 3 | 3 |
| 32 | 4 | 3 | 3 |
| 40 | 5 | 4 | 3 |
| 48 | 6 | 4 | 3 |
| 64 | 8 | 6 | 4 |
| 76 | 10 | 7 | 5 |
| 90 | 12 | 8 | 6 |
The table above applies those steps to licensed sizes common in the seven-county Birmingham area, where SCALF licenses on ADPH's roster run from 14 beds in a small group home to 90 beds in the largest congregate memory care license. Our facility pages compute the minimum for each SCALF's licensed bed count, assuming every bed is full.
Who counts as staff?
The table counts staff on duty, which is why it is worth asking who exactly is included. Ask whether the nurse, the activities director and the receptionist are counted toward the minimum, or only direct care staff on the unit. Ask whether staff are shared with an assisted living building on the same campus, and how the facility ensures a lockable wing has its own staff.
Every SCALF must also employ at least one registered nurse, who may serve as administrator or care coordinator but not both, and a medical director who is an Alabama-licensed physician. The RN assesses each resident monthly and writes the care plans, so ask how many hours a week the RN is in the building.
Training matters as much as headcount
Before any resident contact, every SCALF employee must complete the Dementia Education and Training Act (DETA) Care Series developed by the Alabama Department of Mental Health or an approved equivalent. Licensed staff also complete the DETA Brain Series, a course on the pharmacological management of dementia and the Dementia Assessment Series. Training records, attendance and post-tests must be kept.
A fully staffed shift of untrained workers is not what the rule intends. Ask to see the training log for the most recent hires, and ask how quickly new employees finish DETA before they work the floor.
How to check staffing on a visit
Visit at shift change, around 3 PM or 11 PM if you can, and count. Ask for the staffing schedule for the memory care unit, which Alabama rules require facilities to post and keep for six months. Compare the number on duty with the census that day, not just the licensed beds.
Then read the facility's newest statement of deficiencies. Personnel and training is one of the most frequently cited rule areas in the SCALF reports we reviewed around Birmingham, after care of residents and records. If staffing or training tags appear, ask what changed.
Frequently asked questions
What is the minimum memory care staffing in Alabama?
Two staff on every shift for 1 to 16 residents, three for up to 24 residents on days, 36 on evenings and 48 overnight, then one more for each additional 8, 12 or 16 residents, under Table A of rule 420-5-20-.04. More staff are required whenever residents' needs demand it.
Does Table A apply to regular assisted living?
No. Regular Alabama ALFs have no numeric ratio; the rule requires staff on duty 24 hours a day to meet residents' needs, at least one CPR-certified person at all times and enough staff to evacuate residents.
Must an Alabama memory care facility have a nurse?
Yes. Each SCALF must have at least one registered nurse and a physician medical director. A nurse practitioner or physician assistant may not serve as medical director.
How can I see a facility's staffing schedule?
Ask for it. Alabama's rules require facilities to post the employee schedule showing names, days and hours, and to keep it for six months after use.
