Please accept these comments submitted on behalf of the Virginia Hospital & Healthcare Association (“VHHA”) in reference to the Virginia Board of Health’s proposed amendments to 12 VAC 5-230, State Medical Facilities Plan (“SMFP”) regulations.  These amendments would “correct several definitions in relation to cardiac catheterization, and add some new definitions,” as well as, make changes “to the occupancy standard utilized for determining the need for new nursing home beds.” 

VHHA submitted public comment in the previous stage.  We are appreciative that the Department has clarified in response to those comments that the newly amended SMFP language will not be retroactively enforced.  We have no further comments at this time.

Thank you again for this opportunity to comment.

Sincerely,

R. Brent Rawlings

Senior Vice President & General Counsel