12VAC35-105-520 (A): Risk Management

We are seeking clarification regarding the relevant timelines associated with 12VAC35-105-520 (A) risk manager training requirements which states, “the provider shall designate a person responsible for the risk management function who has completed department approved training which shall include training related to risk management, understanding of individual risk screening, conducting investigations, root cause analysis, and the use of data to identify risk patterns and trends.”  We request that the Department allow for at least 30 days from when a new staff member is hired into the position and/or when the training is available for completion in order to satisfy the requirements in this section. 

12VAC35-105-520 (D): Risk Management

The regulation was amended to read, “D. The systemic risk assessment process shall incorporate uniform risk triggers and thresholds as defined by the department.” Regarding the systemic risk assessment section we are seeking clarification regarding the Department notification process for thresholds and risk triggers.  We ask that the Department allow for a 90 day period from point of notification to allow for the providers to make any and all appropriate adjustments to the risk assessment processes and plans.