The newly proposed regulations do not promote individualized treatment, where the resident is at the center of their treatment plan.  Providers should be allowed the flexibility to provide services that achieve the desired goals and outcomes for each individual.  I would recommend that the Behavioral Health Services Administrator be granted the authority to review each Service Authorization Request, and review admission and continued stay based on the programming that is being proposed by the provider.  Providers should have the opportunity to justify their clinical decisions based on the individualized needs of the resident.  Additionally, active treatment should be the focus of care.  To this end, I also recommend that we consider speaking with individuals here in Virginia that receive services.  Seek their feedback regarding the current regulations and treatment regimen.  How do they feel about the current academic and therapeutic structure while in treatment?