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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  2:29 pm
Commenter: Jeremy Cromer

12VAC35-105-170 H. and 620D.3
 

There are two related substantive changes (12VAC35-105-170 H. and 620D.3 ) from the version of the regulations published 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 unrealistic. Providers can minimize the possibility, but can’t guarantee that a plan will prevent a recurrence. In this line of work there are so many unpredictable variables that it virtually impossible to have this expectation of perfection. 

CommentID: 84105