|Action||Compliance with Virginia’s Settlement Agreement with US DOJ|
|Comment Period||Ends 7/22/2020|
Corrective Action Plans
Implement CAP by the date of completion indicated in the plan; Guidance – For serious injuries and deaths resulting from substantiated abuse/neglect/health & safety violations, OL verifies corrective action plans have been implemented within 45 days of their start date
- Is it the responsibility of the agency or the specialist to ensure that the specialist has verified the CAP has been implemented?
H. Provider shall monitor implementation and effectiveness of CAP … If provider determines that an approved CAP was fully implemented but did not prevent the recurrence of a regulatory violation or correct any systemic deficiencies, the provider shall: continue plan and put into place additional measures to prevent the recurrence of cited violation and address identified systemic deficiencies; or submit a revised corrective action plan to the department for approval
- Wouldn’t a recurrence of a cited violation result in a new citation that is now deemed “systemic” if it is the 2nd time in less than 2 years?
- If the CAP did not prevent a recurrence of the regulatory violation, would submission of a revised CAP prior to a new citation being written prevent an additional citation?