12VAC35-109-80 ISP Requirements 

E.2 Provider shall test the employee or contractor's knowledge, competency, or both and retain documentation of test with in the employees file. 

• Please consider removing this regulation. Implementation of this regulation would require an persons served information to be kept in a staff members personnel file outside of the program. This regulation will also cause an undue hardship on providers with mangers having to create a test for every person served as well as HR departments having too track and log all test. The total amount of test that would need to be created and tracked could be in the hundreds annually.