12VAC35-105-10 - recommendation to adding a definition for support decision making to this section

12VAC35-105-40 - recommendation changing medical condition to medical symptoms.

12VAC35-105-60 - add "and available" after if applicable

12VAC35-105-70 - A. #1 & #2 recommend changing 24 hour after admission to 1 business day

12VAC35-105-80 - While I agree employees should be knowledgeable about the contents of the ISP for individuals served, establishing expectations to train and test all employees involved in service delivery is an unrealistic expectation that will significantly distract from service delivery. Observations of knowledge and competency about providing the service is part of supervisory and performance evaluation. Moving forward with this is likely to reduce updates to ISPs. This places an undue burden on Human Resources and supervisors, who would have to develop ways to test and train employees while maintaining their other responsibilities.

12VAC35-105-90 - asking for clarification if quarterlies are required for this service. 

12VAC35-105-100 -

B5. Clarification on what services would be beneficial such as outpatient but not day support. This is an impractical expectation for daily service documentation.

B6 - replace clinical staff to qualified staff

C - add informational notes along with communication logs and supervisory notes.

12VAC35-105-120 - A #3 & #4 - recommend to remove will provide as we cannot provide medical or dental services as we are not medical professionals. 

12VAC35-105-130 - 2 b.  remove as this pertains to residential services not centered based services 

12VAC35-105-150 - recommendation to make consistent through DBHDS regulations. The temperature range is different for center based services than residential services. 

12VAC35-105-200 - G. This is an impractical expectation for programs due to the administrative burden. This is not required for any other DBHDS licensed service, request this be removed.