In additions to agreeing with the concerns already mentioned about 1) fire inspections; 2) risk manager qualifications; 3) fire marshall inspections for all levels of residential programs; 4) lack of DBHDS training around risk thresholds; 4) QDDP qualifications and 5) the addition of ABAs, the VACSB regulatory committee makes the following comments:

The impact stated in the NOIRA is not representative of the true impact to CSBs. DBHDS has increased regulatory oversight through all their Departments.  The impact providers feel from OL, OHR, and Disability Program areas is significant.  The system changes - whether as a result of DOJ settlement, STEP-VA, Medicaid MCOs,, etc are affecting administrative infrastructure in all CSBs. 

There is a lack of consistency in the interpretation of these regulations by DBHDS staff in various regions which leads to increased confusion and misinformation.  Recommend continued guidance documents and written responses to CSB questions be published when there is a discrepancy noted.

CSBs have increased staff in their QA and Admin Departments to meet current expectations and continuously evaluate workload based upon regulatory requirements.  CSBs and private providers consider very carefully the impact of service delivery by adding administrative positions vs. adding positions that provide direct client care.  Mandated reporting time frames take precedent over other duties to include: 24 hour CHRIS reporting, 10 day mortality review response, 30 day RCA, licensing citation response - all of which are examples of what is required to be managed.  The system has seemed to evolve to responding to citations and less about quality improvement.  Requiring all ER visits, for example, will add undue burden to the system. 

While timeframes exist in earnest for CSBs, the heavy administrative burden for DBHDS is affecting their ability to respond to requests in a timely manner to include accuracy of licenses.