In response to 12 VAC 35-105-620 D3

The proposed regulations support an adversarial relationship between providers and DBHDS and foster a fear-based mentality in response to errors. The best outcomes for clients will be achieved through a collaborative relationship between providers and regulatory professionals, one in which improvements can be made with support and guidance. Providers are in a position to mitigate risk through corrective action plans; however, preventing the re-occurrence of a subsequent mistake is unrealistic, especially over an extended period of time.