The Virginia Association of Community-Based Providers (VACBP) represents private-sector providers of behavioral health, substance use disorder and ABA services throughout the Commonwealth of Virginia. We appreciate the opportunity to share the following comments on the proposed regulations to the Center-Based Service chapter of the licensing regulations on behalf of our members. Below are some overarching comments that are reflected in the specific comments provided.

• The licensing regulations should use consistent and clear terminology that is well known and understood by providers.

• It’s important that the licensing regulations reflect the distinct differences between center-based services and residential or in-patient services, for example, hours of operation.

• Given the extensive requirements and oversight provided through the major accrediting bodies, flexibility in the licensing regulations should be allowed for agencies with proof of accreditation in good standing. This may include relief from initial and periodic licensing inspections, inspections of agency locations and client documentation requirements outlined in the regulations.