105-20  Definition of Serious Incident. An emergency room visit; or urgent care facility visit when not used in lieu of a primary care physician visit. The change back to all emergency room visits increases the amount of incident reports submitted as well as the amount of staff time in writing and reviewing the incident for the root cause analysis. 

12VAC35-105-320. Fire inspections. The provider shall document at the time of its original application and annually thereafter that buildings and equipment in residential service locations serving more than eight individuals are maintained in accordance with the Virginia Statewide Fire Prevention Code (13VAC5-51). This change for Sponsored Residential has caused confusion across the state  related to the new addition of Sponsored Residential in this regulation. Fire Marshalls will often refuse to visit a family home. Please consider making Sponsored Residential Homes exempt from this regulation. 

105-520 - Risk Management. The wording in the regulations “incorporate uniform risk triggers and thresholds as defined by the department”, recommend to be removed or better defined for clarification. 

105-650 - Assessment Policy. A comprehensive assessment shall update and finalize the initial assessment. There are questions regarding this requirement and Same Day Access process.  There has been confusion if two separate assessments are required (the initial assessment and the comprehensive assessment.) This needs clarification as it relates to the SDA process.