12VAC35-105-960.D This change in language that does not specify a "physical examination" and instead states an "examination" can be manipulated by the provider, it is important to specify a physical examination.  

12VAC35-105-970. The individual's progress in treatment should still be documented and evaluated.  This should be specified in the regulation.  

12VAC35-105-990. Regular attendance of counseling in accordance to an Indvidual's treatment plan should be taken into consideration of take homes, given that it has been clinically proven that counseling as a combination of MAT is the most successful for recovery.  Also, the other additions that state "absence of" how is the treatment provider determining there is an "absence of" this needs to be defined more....is it by assessment? and if so, what type of assessment?