The MPNN CSB would like to respectfully appeal the proposed Medication Administration within 30 calendar days of hire.  As this proposed regulation resides in the General Chapter 12VAC35-106-290, it makes it mandatory for all clinically oriented staff, rather than the select few who will actually be tasked with administration of medications.  We believe this is both unnecessary for the vast majority of staff and poses a potential safety risk in that staff with no assigned professional duties in the realm of medication administration, now having the certification to do so.  We believe that this training needs to be targeted to only those presented with this responsibility.  If the purpose behind this regulatory proposal is a clinical work force with increased medication awareness, we do see the benefit to all service staff having a better understanding of basic terminology, types of medications, and common side effects, and would not be opposed to such a training mandate.  We thank you for your time and consideration.