Virginia Regulatory Town Hall
Department of Behavioral Health and Developmental Services
State Board of Behavioral Health and Developmental Services
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
Previous Comment     Next Comment     Back to List of Comments
7/21/20  11:22 am
Commenter: Melissa Blackburn

Excessive and not possible for every scenario

The proposed language change is excessive and will result in repeated citations.  All providers should (and do) take measures to try to prevent future occurrences of any violations, however with multiple variables, it may be hard to prevent the violation from occurring again.  The proposed language change sets providers up for failure; repeated citations and CAPs will only result in providers focusing on paperwork/policy changes and potentially reduce the provider's ability to provide quality services.  Providers are tasked with continued responsibilities but are extremely underfunded and any and all language changes result in more work for the provider with no additional resources.  Again, this proposed change is too risky and excessive.  

CommentID: 83921