106-260 Contracted Employees....

C. When a provider uses staff employed by a contractor or temporary agency, the provider shall ensure a method to obtain all the elements in 12VAC35-106-240 A so that the provider may have a copy of the contractor’s personnel record for its files.

Feedback: This requirement would necessitate considerable changes to existing processes involved in bringing on contract employees and these changes would require additional staff time and therefore cost to provider agencies.  These requirements would also substantially protract the hiring process meaning that key positions providing direct client service will remain vacant longer.

106-270 Students and volunteers...

C. The provider shall conduct a criminal background and a check of registry that is maintained by the Department of Social Services pursuant to Code of Virginia § 63.2-1515 for all students and volunteers. The provider shall follow the written policy for criminal history background checks and registry searches required by 12VAC35-106-240 B with regards to results obtained.

Feedback: this provision will increase cost in staff time.

106-300 Employee training...

. Required initial training: Within 7 business days following an employee or contractor’s start date, each employee or contractor responsible for supervision of individuals receiving services shall receive basic orientation and training regarding: a) the provider’s behavior intervention policies procedures and techniques regarding less restrictive interventions, timeout, and physical restraint; b) Cardiopulmonary resuscitation (CPR) and first aid training issued by the American Red Cross, the American Heart Association, or comparable authority in standard first aid and CPR. The training shall have a certification process which shall include a hands-on, in-person demonstration of CPR competency. Employees who are certified as an emergency medical technician shall be deemed to have fulfilled this requirement; and c) medication administration including basic pharmacology and medication side effects.

2. Within 14 business days following an employee or contractor’s start date, the provider shall conduct emergency preparedness and response training that shall include:

c. Using, maintaining, and operating emergency equipment as appropriate for the service setting and indiviuals served;

C. There shall be at least one employee or contractor on duty at each location who holds a current certificate (i) issued by the American Red Cross, the American Heart Association, or comparable authority in standard first aid and cardiopulmonary resuscitation (CPR) or (ii) as an emergency medical technician. A licensed medical professional who holds a current professional license shall be deemed to hold a current certificate in first aid, but not in CPR. The certification process shall include a hands-on, in-person demonstration of first aid and CPR competency. All employees, contractors, students, and volunteers shall complete an annual training that shall include:

1. Retraining of all the elements required within 12VAC30-106-300 B 1-3; and

Feedback: Keep requirement for initial CPR and first aid training to current 15 business days, not 7 days.  Proposed change will delay the ability to start staff to fill critical positions, as this training is not always available within 7 business days of start date. 

Typo in ‘c”.

Require re-training of first aid and CPR before credential is expired.  The additional of all of the re-trainings on an annual basis adds considerable cost in staff time and is burdensome.