We support DBHDS's intent to structure the licensing regulations into separate chapters. We are supportive of proposed actions Virginia's behavioral health and developmental disability services for long-term modernization. We urge DBHDS to be mindful when creating the chapters to clearly distinguish between services that may fall under two categories (for example crisis residential services which are both residential and crisis).

The NOIRA bulletin mentions reviews that have occurred as far back as 2017. We urge DBHDS to thoughtfully review the previous drafts shared with the public. Many codes and regulations have changed between 2017 and 2025 and the some of the content in the draft regulations and comments from 2019 and 2021 may be obsolete.