vaACCSES Comments -
July 22, 2021
Proposed Licensing Regulations 12VAC35-107 - Residential Services Chapter

12VAC35-107-50 Secondary Screening
Comment: Required when someone is placed on waitlist?  An additional administrative burden when there may be staffing issues already present.

12VAC35-107-70
Comment: Concern with two plans for support (ISPs) - initial and then comprehensive?

12VAC35-107-80 (E) ISP Requirement  

Comment: We agree that staff should be knowledgeable about the contents of the ISPs for the individuals served. Adding the addition of testing after each training is an unreasonable expectation and is an significant administrative burden to providers. Knowledge can be verified through observation during the supervisory and evaluation process. Please delete this requirement. 

12VAC35-107-100 - Progress Notes and Other Documentation
Comment: New requirement that progress notes be entered a minimum of once per shift.--- is this  practical or manageable?  The format of progress notes across all locations of one service is desirable but should be reasonable. The format and timing of notes across various services operated under a single organizational license may need to differ in order to reflect the unique nature of each service and affiliated requirements from pay sources.

12VAC35-107-170 B. 2. & 3.
Comment:  Contradiction - “Menus that must be followed and created in advance” - Yet we are seeking community-based services in which people change their minds when they want to and have access to whatever foods they so choose.

12VAC35-107-290 0. Another added expense?  What is the requirement here attempting to achieve?