The progressive actions for citations in violation of 12VAC35-105-160D.2 or 12VAC35-45-1070.c are too punitive and do not take leave room for human error or even with possible corrective action plans in place from prior citations. The standard of no less than 4 occurrences in a two year period will be an impossible one to keep for providers and if enforced as written could have a negative effect on the provider availability for individuals with disabilities.  It is already difficulty enough to find and train staff as a provider in a field that is already struggling to pay the work force at a competitive rate without having to make no more than 4 honest errors in the course of two years without having to worry about your license being suspended.