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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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7/22/20  11:59 am
Commenter: Dana Dewing, Harrisonburg-Rockingham CSB

170 H & 620 D.3
 

A CAP is meant to describe the steps that will be taken to DECREASE the possibility that a problem will occur again.  It is impossible, due to many factors (including human behavior), to expect a problem to NEVER occur again.  And failure to meet the expectation of a problem never reoccuring causing another citation is unreasonable and not realistic.  The expectation for a problem to never occur again is an impossible standard to meet.  12VAC35-105-170H & 12VAC35-105-620D.3 should be removed from the final regulations.

CommentID: 84059