The guidance in this document highlights the accuracy a provider has to ensure to mitigate risk and correct errors.  How will accuracy across DBHDS be ensured?  Historically there have been variances between the instruction given by advocates, specialists, and even the guidance documents provided by DBHDS.  With the addition of another entity (the IMU) there is an increased chance of contradictions.  Beyond the mitigation that can be requested with the specialist's supervisor what path is there for the provider if there are discrepancies between offices?

“H. The provider shall monitor implementation and effectiveness of approved corrective actions as part of its quality improvement program required by 12VAC35-105-620. If the provider determines that an approved corrective action was fully implemented, but did not prevent the recurrence of a regulatory violation or correct any systemic deficiencies, the provider shall”

Again, the idea of total prevention is infeasible.  The individuals and DSP who support them are all human.  No CAP can account for all factors and eliminate all error.  While providers strive for excellence and to meet all standards; prevention is an impossible standard.