Our comment related to licensed professionals doing capacity evaluations: 12VAC35-115-145 B

By utilizing Section 54.1-2983.2 this uses medical language that is less applicable to CSBs and private providers.  Is the attending physician the same as capacity reviewer or is it an either/or situation as in D below it?  Recommend clarifying and allowing that licensed professionals can be the capacity reviewer as this will impact a CSB or private provider’s ability to designate authorized representatives.  Most providers don’t have an attending physician.  These regs seem to imply that this process starts with a physician rather than other providers within an organization.