12VAC35-109-80. ISP Requirements:

In Section A. regarding "Initial ISP", please consider revising language to include if the comprehensive ISP includes all elements of the initial ISP and is written in place of the initial ISP the "Initial ISP" is is not required.  Requiring an initial ISP separate from a comprehensive ISP could be burdensome to the client and provider.

In Section E, 1-3. regarding documented training surrounding each individual's ISP w/ a test is an administrative burden to the provider and may encourage less revising of the ISP when we want to encourage revising the ISP when this is needed (we want to be client centered).  Training surrounding ISP writing and implementation should be done at orientation and then at supervision level regularly.

12VAC35-120, 12VAC35-130, 12VAC35-180

Please consider revising language within these regulations as it appears to be heavily focused on residential treatment vs. "outpatient" center-based services. (i.e. 12 VAC35-120, Section A. 3 & 4, 12VAC35-130, Section 2b & 4c.)

Thank you for the opportunity to comment!