12VAC 35 105-160 - Root cause analysis for all serious incidents in all tiers for all DBHDS licensed will result in extraordinary administrative burden. Recommend defining root cause analysis for specific tiers

-320 is there a time expectation by which all individuals would need to be evacuated?  That would inform how to define "adequate staff"

- 400 - Wording of checks completed prior to hiring of staff - will result in bottleneck of waiting for background checks to return - vs. language that would indicate continued employment contingent upon...

- 520 - A.-Will there be specified curriculum or DBHDS training in order to qualify someone as an expert in all spheres?

- 520 - C- Definition of "adequacy of staffing"?  HIgh risk understandably points out seclusion and restraint - any other definition of "high risk"?

650 - F- 7 g - Definition of restrictive protocols and special supervision requirements?

660 - C - "alternative services" - does that include services not available  or affordable? 

675 A-  re: reassessments, includes language "or other" change in status.  Does that include housing?  Job?  Social?  How to apply across all service provision?

675 - 3 - define team members . Applying to all services is extraordinary.  Time frame of when team meeting would be expected to occur?

1245 - Would that require case managers to be assessing all Part Vs?

It is understood the intent of these emergency regulations are to respond to the SA.  For CSBs, it needs to be noted the regulations also effect all licensed services.