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  2:52 pm
Commenter: Christina Nicol

Proposed final regulations

Please consider two business days instead of 24 hours for filling CHRIS reports. Not everyone has access to CHRIS wen they are not at their office. Also, many times providers do not have all the facts in 24 hours and are not providing a thorough report. Please also consider allowing at least 72 hours preferably longer for updates. It can take longer than 48 hours to get medical testing results back from health care providers. 

The progressive discipline that is proposed is excessive: four citations on late reporting within two years and providers could face severe consequences. Is it worth shutting down a provider that provides good care to individuals because they were late 4 ties in 2 years? If a provider is late 4 times in 6 months that should be grounds for disciplinary actions. Providers need support not a judge and jury. 

There seems to be more concern over times stamps and "I got you" than a partnership to ensure all individuals receive the best care possible. Providers and the Department need to be partners now more than ever. Let's work together to help solve problems and concerns of our individuals. 

CommentID: 84115