As a provider who works with some of the State’s most challenging and vulnerable population, I am very concerned with the proposed legislation that appears to change our relationship with the State agencies.  With the current environment and pressures associated with meeting the needs of children and adolescents while also coping with COVID19,  it surprises me that legislators would push for such a punitive stance.   As providers, we  are required to develop and maintain a Quality Improvement Program.  The core concept of quality improvement is that organizations utilize a systematic approach to identify deficiencies and implement plans addressed towards continuous improvement in reducing/eliminating the deficiency.  Even the best Quality Improvement Program cannot guarantee that a deficiency will never occur again.  More importantly, we are constantly re-evaluating our programs to ensure that we are constantly making improvements and we do this in a  collaborative relationship with our licensing agent.  I am  concerned, based on the language in the proposed regulation, that this process would become  adversarial and punitive, which would be very counterproductive.