The addition of the new provision in Section H of 12VAC35-105 - 170 regarding Corrective Action Plans" is overly directive.  Section G already provides that "The provider shall monitor implementation of approved corrective action and include a plan for monitoring in its quality assurance activities  . . ."  There is a big difference between "minimizing" the risk of an occurrence of an identified problem and the complete "prevention"
of such an occurrence.  Monitoring compliance with a CAP is reasonable, but requiring complete prevention is a standard which can't be met.

 12VAC35-105-520 paragraph A states that the designated person responsible for risk management will “complete department approved training.”  DBHDS needs to clarify what qualifies as an approved training in order to assure consistency across all providers. It would be helpful if DBHDS provided the training to assure this consistency and to facilitate compliance.