12VAC35-105-520. Risk Management A:
Loudoun County MHSADS is seeking clarity in the wording of section A in three areas:
12VAC35-105-520. Risk Management C:
Regarding Section C(1): Environment of Care, we ask that the guidance is tailored to the type of service being provided and reflect that the provider is only responsible for the environment of care for which they have control. For example, as a provider, we do not have the ability to manipulate the environment in an individual’s home or require refrigerator temperature checks in the community.
Regarding Section C(2): Clinical Assessment or Reassessment, the review of individual health risks should be conducted by the treatment team rather than a risk manager. While the risk manager should look to see if assessments are completed and plans changed, they would not be reviewing individual health risks. Please clarify the responsibilities of the risk manager when it comes to the review of the individual’s health risks.
Regarding Section C(4): Use of High Risk Procedures, we are seeking clarity as to what besides seclusion and restraint is perceived as a high risk procedure. We ask that DBHDS provide in the guidance some examples of the ‘other high risk procedures’ they would consider applicable to this section.
Regarding Section C(6): Uniform Risks and Triggers, we are seeing more information. We are unable to comment about whether this is an appropriate task to be completed and included for the overall risk manager unless DBHDS identifies what is considered uniform risk triggers and thresholds and what the expectations will be regarding these.