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 Ended on 7/22/2020
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7/22/20  6:04 pm
Commenter: Brooke Mitchell, Loudoun County MHSADS

Comments regarding 12VAC35-105-665: ISP requirements

We are seeking guidance regarding Section (D) of this provision which calls for a demonstrable working knowledge of the detailed health and safety protocols within an individual’s current ISP.  Of concern is the lack of measurability in this provision.  We are seeking clarification as to the test by which this standard will be measured as there is concern that what one individual considers detailed may not be considered detailed by another.  We believe that without a measureable standard this provision will be difficult to monitor and implement in a consistent manner across the state.  For this reason we ask for guidance and clarification as to what will be the standards set for this provision. 

CommentID: 84170