In the Economic Review form it states that no direct cost will be associated with the change of reporting “peer to peer” as neglect. While that is vehemently not true, it continues to show the disconnect from DBHDS over reaching regulations and the day to day implications of those requirements.

In regards to this document alone, a larger agency will have a rate of peer to peer incidents will be higher due to sheer number of persons served. Then requiring an investigation behind the incidents will have a direct impact on agency due to more Quality Improvement staff will need to be hired to cover the work load.

Now, take into account the other regulations that are already being enforced, Quality Improvement departments are already reviewing an overwhelming amount of data regarding day to day occurrences of the individuals supported.

Lastly and compounding circumstances, is that individuals whom are exiting school or already receiving services have behavioral and/or medical concerns that are extensive. Thus, many individuals cannot be supported in the current models Virginia has laid out with the lack of funding for high supports medically or behaviorally. Providers receive the same response “well you should apply for customized rate” and if anyone at DBHDS knew how arduous the process is to receive denials over and over is for individual who overwhelmingly need additional supports, the system would be overhauled. Every second and penny is scrutinized when providers are just trying to keep doors open and pay staff a livable wage.

In a post COVID world, providers are trying to keep doors open and support communities where they are at, and providers cannot do that with continued regulations that smother the workforce and force the creation of new positions when agencies are already operating on a fiscal year deficit. As a solution, there should be a financial increase related to additional positions created to meet standards or instead of being totalitarian in thinking and regulations, should have a joint action or alliance to work through potential resolutions in a collaborative way.