Virginia Regulatory Town Hall
Agency
Department of Behavioral Health and Developmental Services
 
Board
State Board of Behavioral Health and Developmental Services
 
chapter
Rules and Regulations For Licensing Providers by the Department of Behavioral Health and Developmental Services [12 VAC 35 ‑ 105]
Action Compliance with Virginia’s Settlement Agreement with US DOJ
Stage Final
Comment Period Ended on 7/22/2020
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7/20/20  3:20 pm
Commenter: Hartwood Foundation, Inc.

Unreasonable Standard in 12 VAC35-105-170
 

The new/revised language in regulation 12 VAC35-105-170 now states that providers, in their corrective action plans, must detail measures to prevent recurrences of a cited action/inaction. While providers can and must certainly develop and implement plans to reduce the likelihood of a recurrence of any event which resulted in a citation, there are entirely too many variables, including the fact that many providers operate multiple sites, for a provider to attest to being able to prevent a recurrence. The standard is simply unreasonable if not unattainable. 

CommentID: 83910