Begins 6/15/20 when the regulations are out for open comment? This is overly punitive and unenforceable when the document indicates a future draft date and the regulations are not even approved yet.

When does the “previously cited” 2 year period begin – 6/15/20 or the 2 year period before this date?

It is unreasonable and inappropriate to apply this set of progressive actions as a single standard to the multitude of agencies across VA that may range from a handful of staff to more than 500 who may serve less than 100 individual to more than 10,000 per year.  3 violations within a 2 year period in a very large agency should not be considered systemic where 3 violations in a very small agency may truly be an indicator of a systemic problem.

Citing an agency for failing to implement a CAP for a 2^nd violation potentially does not allow for the time for the corrective action to be implemented depending on the timeline of when the 1^st violation and 2^nd violation occurred.

Mandated Incident Reporting training with cost borne by agency – How will this be determined - is there an approved provider of this training? Is the training to be required of all staff or just the staff related to the violations? (Assuming it will be required for everyone at the agency as they are considering these systemic violations at this point, but can’t hurt to ask?)