I am a parent of a child with DD, as well as a professional in this industry.  Although, there have been numerous discussions between the State and Agency Stakeholders to address a crosswalk document to offer additional guidance on implementation of the regulations it is clearly noted in this document that there is increased regulatory oversight as opposed to clarification or guidance.

With the noted guidance, this will have an impact not only on service providers but on those receiving said services.  As a parent I would rather see the current regulations enforced than additional regulations added to agencies to overburden them to the extent that the care of my child suffers.

12VAC35-105-170 Guidance:

When writing a CAP, to assume that all things that arise are related to a systemic concern and require a systemic plan unnecessarily burdens the system as it could be related to one staff or one maintenance item that could be easily remedied without updating policies or procedure manuals or retraining an entire agency of staff.  The current procedure for corrective action plan development and implementation often remedies a particular situation.

As with the current regulations that are up for comment, the word prevent is noted within this guidance document and should be changed to mitigate or minimize risk as we are working with people and we cannot prevent something from occurring.  Additionally, this document continues to reference progressive citations when a provider is seeking guidance to get an accepted corrective action plan if the provider does not meet the criteria after several attempts then an additional CAP will be implemented.