Family Sharing, Inc. Response to Proposed Changes for Rules and Regulations For Licensing Providers by the Department of Behavioral Health and Developmental Services

Family Sharing, Inc. would like to submit the following comments in response to the Open Comment.  For any questions related to this document, you may contact either of the following members: 

Meneika Keith, Family Sharing, Inc., familysharingmk@gmail.com, 540-414-4561

Deborah Brinkley, Family Sharing, Inc., familysharingdb@gmail.com, 540-414-5552

12VAC35-105-691. Transition of individuals among service.

Family Sharing, Inc. requests consideration to add language related to transitioning individuals due to an emergency, such as the death of a caregiver, abuse investigations, or termination of contract for serious violations to regulations.  During such times, providers attempt to contact decision makers and support coordinators/supervisors/directors but may not be able to reach them due to the timing of the incidents, such as weekends/holidays.  The current provider of residential services is responsible for the residential provision and safety of the individual in services and must, during these times, take action to secure a temporary placement within the provider’s agency that can provide residential support until transitional planning can be implemented.  Currently, a provider who is faced with the need to place someone temporarily into an emergency placement licensed within their agency can be cited for moving an individual without following proper protocol but is also at risk of being cited for neglect of individuals that they either (a) do not move from such an emergency situation or (b) abandon to another agency the responsibility for finding alternate residential supports.

Family Sharing, Inc. suggests the provision of emergency transition protocols which include acknowledgment of the responsibility of the current provider of residential supports to assure safe residential placement during an emergency which dictates a requirement for a move from their current location, requirement that the provider be able to document attempts to contact team members and decision makers for collaboration, and a time line for returning to the normal transition protocols of touring homes and assuring vendor choice and transitional meetings while the individual is in an emergency placement within the same provider service.