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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7/22/20  7:48 pm
Commenter: Sarah Shires, Key Living Options Inc.

proposed changes to regulations

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Providers are held responsible to complete and implement Quality Improvement Plans and reviews of Level 1 reports, Root cause analysis for level II and level III reporting, Risk management plan, and CAPS. This puts an unnecessary burden on providers to complete all of these as a separate regulation. Most of the agenda listed above is a repeat of the same issues that need to be addressed for the company and the individuals served. Providers should be expected to review all issues and concerns but it should be under one regulation. In regulation it should be clearly defined , with detail of expectations and completion deadline. Separate regulations puts undue pressure on the provider and takes precious time away from individuals . Having so many different regulations on the same issue is confusing for providers and can cause more CAPS than unnecessary.


I also don’t think it is realistic for providers to pick one person to be responsible for risk management when in many companies many individuals are involved. The regulation also states completed department approved training. Has this training happened and if not how long will providers have to complete this training and how often will it need to be completed?

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CommentID: 84176