12VAC35-105-210. F- Making the amendments suggested significantly puts residents of residential programs at risk.  Not having an appropriate audit by a CPA or having someone oversee the program that is bonded and indemnified is bad business practice and in fact is NOT the same thing as indemnity coverage of a business as a whole.  It is suggested that DBHDS does a little more research than removing this language.  There are several times where residential providers, specifically of ID/DD are intermingling the residents own funds (personal, SS, etc.) with the companies funds, which in accounting practices is considered not in GAAP appropriate practices.  Holding providers accountable with maintaining practices that protect those they serve should be considered.  

2VAC35-105-430

This removal and changes within this section claim to be duplicative, which they are not.  This regulations is what is required in the personnel record.  The other regulations just state they have to be done, not that it has to be in the record.  Without saying that something needs to specifically be in the personnel record, DBHDS cannot cite a provider for not having it.