The Virginia Association of Community Services Boards has concerns with the proposed emergency regulations per the following:

§320 
Request that “The provider shall ensure adequate staff to safely evacuate all individuals during an emergency” 

§20 
Request insertion of “unplanned” before the phrase “hospital admission”; individuals are admitted to the hospital for procedures that, while they may be critical to an individual’s health, are not serious incidents.

Request that reporting of a “disaster, fire emergency or other condition that may jeopardize the health, safety or welfare,” be removed from these regulations as it is already required to be reported in 12VAC35-105-530 F and requiring it in this context would require, for example, a report for each individual in a group home.  

§160 E
Request the insertion of “level 2 or level 3” before the phrase “serious incident” to clarify that a root cause analysis is not necessary for level 1 critical incidents.

§400 E
A provider would realistically not be able to comply with these regulations as written.

Results of these background checks are not received prior to hiring nor are they received prior to the individual beginning his/her duties.  In addition, current code §19.2-389 designates the acceptance of employment as the driver for determining if the applicant has been convicted of a barrier crime.