Virginia CSBs support the proposed Guide’s efforts to clarify the Customized Rate program, incorporate SIS-A Second Edition mappings, improve provider engagement, publish rate information, and permit biennial approvals for stable cases. DBHDS and DMAS should define objective standards and due-process protections for enhanced monitoring, improvement plans, rate reductions, terminations, and recoupment-related referrals; protect providers through receipt-based deadlines, cure periods, good-cause exceptions, and continuity for timely renewals; account for rural workforce limitations; and publish the rate model, operational examples, WaMS instructions, and implementation training. CSBs and other providers should receive at least 180 days to update staffing, fiscal, documentation, authorization, and compliance systems before enforcement.