Comments on Proposed Compliance with Virginia’s Settlement Agreement with US DOJ
Lutheran Family Services of VA Comments on Proposed Compliance with Virginia’s Settlement Agreement with US DOJ
12VAC35-105-170. Corrective action plan – Often times we receive citations months after events occur. Could OL have deadlines to provide citations? Also, sometimes we don’t hear back in a timely manner as to whether or not a Corrective Action Plan has been accepted. Could OL have deadlines to approve or disapprove?
Serious Incident Level II definition – the proposed change is for all ER visits to be categorized as Level II instead of ER visits in lieu of PCP. Instead of making this change can there be clarification or guidelines for providers to better determine what in lieu of means? This will have an increased burden on providers and the state.
There is a proposed definition for “direct care position” though this term only appears to be used in 12VAC35-105-400 and is something that is proposed to be deleted.
12VAC35-105-620 reference to “statewide performance measures” though these have not been published yet. Can this be removed until the time that they are published, to limit confusion.
