Paragraphs in Section 12VAC35-105-170 seem to not be in agreement.  Section C1 states that a detailed description for the corrective action to be taken that will minimize the possibility that the violations will occur again and correct any systemic deficiencies.

Section H reads that we must prevent the recurrence of a regulatory violation……

Minimize and prevent are not the same thing.  Furthermore, I agree that we should do what we can to minimize all violations but I don’t see how it’s possible to completely prevent a situation for occurring again. Section H should remove “prevent” or remove the section entirely.

Section 12VAC35-105-520 paragraph A states that the designated person responsible for risk management will “complete department approved training.”  Will DBHDS be providi8ng this training? Will there be a list of approved trainings submitted to providers or will you require pre-approval of all trainings? Vague statements like this could become problematic for providers.  We would be in favor if the statement read, “complete training provided by DBHDS.” This would ensure all providers receive the same training, same curriculum, from consistent trainers.

Section 12VAC35-105-620 part D.3. once gain states that we will include “additional measures to prevent the recurrence of the cited violation….”  Once again, this is an impossible standard to meet. Furthermore, not all cited violations are systemic deficiencies. Also, I’m not sure if I read this correctly but for providers with more than one home across multiple locations, this will be impossible to ensure.