12VAC35-105-170 H. and 620 D.3. contain changes that will have a substantial impact on all providers.  Both contain the expectation that providers when cited for violations, will develop and implement a corrective action plan (CAP) that will act to mitigate future occurences. Recurrence prevention is an almost impossible expectation to meet. Agencies can mitigate or minimize risks through plans, but it is a lofty expectation to think that an agency can implement a plan that will absolutely prevent a relapse. Ultimately 12VAC35-105-170 H. and 620 D.3 should be removed from the final regs.