The proposed licensing regulations will have a significant impact on providers as some of the terminology used is inconsistent and unrealistic.  Regulation 12VAC35-105-179.C.1 states "The corrective action plan shall include a detailed description of the corrective action to be taken that will minimize the possibility the violation will occur again and correct any system deficiencies".  Section 170.H.1 uses the term "prevent reocurrances" which is an unrealistic expectation for providers.  Providers strive to provide quality services and keep each individual healthy and safe at all times.  The reality is our best efforts to keep individuals safe can mitigate risk but not prevent it all together.  Please consider removing this language from the regulation in exchange from verbiage which would be more realistic and supportive of providers.  An additional area of concern is the enforcement of citations and progressive action for repeat citations.  The proposed language in 170H and 620D should be removed/revised from the final regulation.