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 Ends 7/22/2020
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7/21/20  1:50 pm
Commenter: Brooke Keen, Wall Residences

Progressive Action for Repeat Citation (language reform/concern)

The language within this document places additional burden upon the provider community. This document moves into regulating through guidance. This language punishes providers who continue to report knowing the risk of citation outside of the 24 or 48 hour time frame. The steps of Progressive Action for Repeat Citations does not take into account agency size including number of locations or programs and places an unreasonable burden on larger providers that is almost impossible to fulfill. If the document is not pulled, it needs rewritten with input from stakeholders and includes language that takes into account provider size in relation to Progressive Action

CommentID: 83982