|Comment Period||Ends 1/22/2020|
1) Asking for clarification to the new language which requires adding a resident's license number to all written communication. (i.e 18VAC115-20-52 B. 10) Does this include clinical documentation/ notes?
2) Same section: The added language regarding informing client that the "resident does not have authority for independent practice and is under supervision" while providing supervisor's name, professional address and phone number, may lead to unnecessary confusion by individual's served as to the qualifications. Curious as to the rationale for the added language. In addition, asking for clarification as to how often the client would need to be provided notice - assumption is only at start of services.
Requirement to add resident's license number
18VAC115-20-52 B. 10: The requirement to add a resident's license number to all written communication seems excessive. Each resident will registered with the board by name and will sign all documentation with legal name. Adding the license number would be time consuming and would not clarify or improve upon the clinical record. Recommendation not to require the resident’s license number be added to all written communication, but only to require legal name and signature.