There are two related substantive changes 12VAC35-105-170H. and 620D) from the version of the regulations published and at the proposed stage which will have a substantial impact on all providers. Both contain the expectation that providers, if cited for any violation of any regulation, will produce and implement a corrective action plan that will prevent recurrence. This is an impossible standard to meet. Providers can minimize the possibility as is stated in 170C but can't guarantee that a plan with prevent a recurrence. 12VAC35-105-620D.3 should be removed from the final regulations and guidance documents produced and up for comment at this time that include reference to these regulations should be pulled and rewritten.