Regarding 12VAC35-105-160D.2 or 12VAC35-45-1070.c, progressive punitive action will most likely be most difficult for smaller, rural providers to navigate. Progressive disciplinary actions sit on the negative side of engagement.  Trainings from DBHDS currently focus on and are centered around the urban areas of the state making access to small rural providers difficult.  Training provides a base that allows opportunity to improve.  Providers are guided by state regulations. We rely on the state to provide clear guidance and training.  Too often mandates are executed before there is clear understanding and subsequent training.  Make training easily accessible in all parts of the state. 

There is inherent risk to living in the greater community for all.  Providers are not only managing risks of staff providing support to people, we are obligated to mitigate the risk of people we support living their life in the community as well.  We all work in a human services field often tasked with providing support for the very basics of human need.  It is impossible to prevent human errors, it is a much more fathomable task to manage and reduce risks.  I believe all providers strive for reduction in errors.