Even for a public health organization like ours, it's a significant effort to pull together the plan and the training within 60 days, even though we were already doing everything required in the plan.  Please consider provided a grace period (perhaps 30 days) for finalization of the plan and implementation of the training on the plan, especially if we can provide documentation that the policies and practices outlined in the plan were largely already in effect.

Our organization employs contact tracers.  Contact tracers are specifically referenced in the Standard among jobs that have direct personal contact.  While in some jurisdictions, contact tracers are going door to door, this is not so much the case in Virginia. Most contact tracing is done by telephone across the country and in Virginia.  I would suggest changing the references to contact tracers to community outreach workers.  

Thank you.