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
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7/22/20  12:24 pm
Commenter: Karen Smith, The Arc of Greater Prince William/INSIGHT, Inc.

Reporting Serious Incidents

It is discouraging that the Department seems to be more concerned about providers adhering to reporting regulations with punitive consequences than supporting the providers to become the best state system possible.  From appearances the Department values proper and timely record keeping more than quality support and care.  

Please consider two business days for reporting into the CHRIS system.  We understand the importance of notification but the 24 hour stipulation and the 48 hour update is unreasonable in many instances.  Oftentimes emergencies happen on weekends and holidays and the providers are more concerned about the individual having to be admitted to the hospital and notifying family members than making certain a CHRIS report is submitted on time.  Updates such as lab reports may not be available with 48 hours.  

Reporting will not prevent things happening to people.  Not everything is under the providers' control and not all providers can access CHRIS away from their worksite.  Please do not make a time stamp more important to providers than giving quality care and attention to the individuals we support.  

The progressive discipline that is proposed is unreasonable:  four citations on late reporting within two years and providers could face severe consequences including possible closure.  Providers, now more than ever, are struggling to provide quality services in an inadequately funded system.  We need the support of the Department to be partners again to help solve problems and concerns, not the "gotcha" mentality these regulations suggest.

CommentID: 84071