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Virginia Regulatory Town Hall
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Department of Behavioral Health and Developmental Services
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State Board of Behavioral Health and Developmental Services
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Rules and Regulations For Licensing Providers by the Department of Behavioral Health and Developmental Services [12 VAC 35 ‑ 105]
Action Compliance with Virginia’s Settlement Agreement with US DOJ
Stage Final
Comment Period Ends 7/22/2020
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7/15/20  11:54 am
Commenter: Rob Slaubaugh Harrisonburg Rockingham CSB

Progressive actions for Repeat Citations sets impossible standard
 

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.

 

CommentID: 83892