In the definitions section of the Center Based updated regulations in the Provider definition the term mental retardation is used - followed by intellectual disability in parenthesis.  I understand that it is reflecting the Code of Virginia definition  - but can we please advocate to have the Code of Virginia definition updated??

12VAC35-109-60 references standardized state assessment tools.  Where can we access these?

12VAC35-109=70 The section discussion alternate services seems like excessive documentation when working with and individual seeking center based day support.  Is this intended for all center based services?

12VAC35-109-B.14  Doesn't seem pertinent to most Center Based Day Support plans.

12VAC35-109-80.E 1 & 2  Training and review of individual service plans is very important and something we do at regular team meetings.  But if I am reading paragraph 2 correctly - we are expected to develop tests specific to each individual training plan and maintain copies of these tests?  Everytime we admit a new individual?  For every staff member that will work with them or be in rotation for coverage?  This really sounds excessive.  Over managing an already administratively burdened group of people.

12VAC35-109-90F.4.b&c  Center based day support initial planning isn't typically focused on discharge planning.  Center based day support is generally long term, with discharge planning discussed when appropriate by the team.  Why add this measure before it is appropriate for the individual?

I value the work done to separate the the regulations into chapter that are more organized and meaningful - but it seems like Group Day Support is so different from other Center Based providers, that maybe a little more division would help.  Great job over all - with updates that were needed.