INITIAL DRAFT: NEW Center-Based Service Specific Chapter (109) for 12VAC35-105, Rules and Regulations for Licensing Providers by the Department of Behavioral Health and Developmental Services

1. Can you please consistently differentiate between the ISP (Individual Support Plan) and PFS (Plan for Supports)? Does the ISP reference what the Support Coordinator is responsible for?
2. Please add a definition for PFS (Plan for Supports)
3. 12VAC35-109-80. ISP requirements. B.14: Projected discharge plan and estimated length of stay within the service.
   1. Should this have “if applicable” after as we do not plan on discharging anyone from Center Based Day Support Services.
4. 12VAC35-109-80. ISP requirements. E. 2. After each training, providers shall test the employee’s or contractor’s knowledge, competency, or both, and retain documentation of the test of the employee’s or contractor’s knowledge, competency, or both within the employee or contractor’s personnel file.
   1. You are asking us to put program participant information into an employee/contractors personnel file. In addition, we are already documenting training of the plan, we review the notes to ensure understanding, all employees and contractors have competencies and other training related to services. Please consider removing this regulation as we should not be placing program participant specific info into personnel files and this adds an additional burden on an already cumbersome job for our managers.
5. 12VAC35-109-90. Reassessments and ISP reviews F.4.b.Individual’s progress towards discharge.
   1. Center Based Day Support does not routinely make plans for discharge, should this say “if applicable”?
6. 12VAC35-109-100 B.5. Describe needed follow-up care or note which objective within the ISP will receive focus the next time the individual receives services;
   1. Should this say “if applicable” as it does not appear to apply to center based day support?
7. 12VAC35-109-130. Emergency preparedness and response plan.
   1. Will you provide an example plan for all of section 130?
8. 12VAC35-109-130 B.1. Annexes dedicated to the highest-priority hazards as indicated by the vulnerability analysis which include documentation of specific plans, policies, and procedures to prevent, mitigate, prepare for, respond to, and recover from the hazards most likely to disrupt provider operations.
   1. Please define annexes.
   2. Who does the vulnerability analysis?
9. 12VAC35-109-130 B.2.a. Documented, current consideration of local and regional sites that could function as evacuation locations or stop-over points, including documentation of any arrangements the provider has made with such sites.
   1. In the event of an emergency or natural disaster we would listen to local news/radio to determine where to go. Gathering this information ahead of time is not helpful in the event of a true emergency as this is likely to change often and based on the type of emergency.
10. 12VAC35-109-130 B.2.b. Policy and procedure for executing an evacuation or individual relocation to include resident and staff tracking and preservation of all critical services (pharmacy, Feeding, etc.).
    1. Please clarify what type of tracking is expected.