There are two related substantive changes (12VAC35-105-170 H. and 620D.3 ) from the version of the regulations published at the proposed stage which will have a substantial impact on all providers. Both contain the expectation that providers, if cited for any violation of any regulation, will produce and implement a corrective action plan that will prevent recurrence. This is unrealistic. Providers can minimize the possibility, but can’t guarantee that a plan will prevent a recurrence. In this line of work there are so many unpredictable variables that it virtually impossible to have this expectation of perfection.