Paragraphs in Section 12VAC35-105-170 do not apear to be in agreement with each other.  Section C1 explains a need for the corrective action to be taken that will Minimize the possibility that the violations will occur again and correct any systemic deficiencies. However as you move on to Section H it uses the phrasing that it must prevent the re-ocurrence of a regulatory violation. While I am in agreement that we should do  our best to minimize all violations  I don’t see how it’s possible to completely prevent a situation for occurring again. Section H should remove  the “prevent”  to come in line with section c1 or the section should be removed. 

Section 12VAC35-105-520 paragraph A sats that the designated person responsible for risk management will need to complete department approved training.  Will DBHDS be the designated provider of this training ?  Will there be a list of approved trainings/ trainers submitted to providers ?   It would be beneficial if the statement read, “complete training provided by DBHDS.” This would ensure all providers receive the same trainings with consistent curriuculms  across the state.

Section 12VAC35-105-620 part D.3. once gain focuses on prevention,  while a nice idea this is an impossible standard to meet as not all  violations resulting in a citation are systemic deficiencies.