Defined Terms:  (comments in bold) 

“Allegation” is not a defined term; however, (please define allegation more clearly as complaint and allegation are being used interchangeably to meet internal review requirement.)

Please define the scope/definition of internal review requirement.

"Neglect" (neglect is defined differently per different entities i.e. MCO’s, social services, board of nursing, etc. this definition is more aligned with negligence/quality of care issue, rather than neglect). means failure by a person, program, or facility operated, licensed, or funded by the department, excluding those operated by the Department of Corrections, responsible for providing services to do so, including nourishment, treatment, care, goods, or services necessary to the health, safety, or welfare of an individual receiving care or treatment for mental illness, intellectual disability, or substance abuse. See § 37.2-100 of the Code of Virginia. Definition should include “directly impacts health/safety of individual” or “results or could result in significant harm to individual”. Medication errors should be included since this is how medication errors are categorized. Additional guidance is needed to clarify expectations around med errors reporting/investigation.

Quality of Care Incident: Any incident that calls into question the competence or professional conduct of a healthcare provider in the course of providing medical services and has adversely affected, or could adversely affect, the health or welfare of a member. These are incidents of a less critical nature than those defined as sentinel events.

Untoward event: unpredictable event that was not preventable.

“Peer-on-peer aggression” means a physical act, verbal threat, or demeaning expression (What does this mean? Please elaborate or clarify) by an individual against or to another individual that causes physical or emotional harm (how to determine this?) to that individual. Examples include hitting, kicking, scratching, and other threatening behavior. (Include non-physical examples that would lead to emotional harm)