Virginia Regulatory Town Hall
Agency
Department of Behavioral Health and Developmental Services
 
Board
State Board of Behavioral Health and Developmental Services
 

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8/7/24  10:39 am
Commenter: Anonymous

Don't agree with suggested edits
 

Might want to change the wording of this document, it says "low hanging fruit" seems somewhat derogatory. 

12VAC35-46-190

Removing this language puts residents at risk.  Several children's residential providers over the last 10 years have opened their practices solely on their projected revenue, the projected revenue for such a service is not predictable.  Given there are several factors that contribute to the admissions to residential providers in which the provider has no control over.  Removing these requirements put residents at significant risk and also risk that the provider can't provide the necessary services and necessities for the resident.  Not holding the provider accountable fiscally has a direct impact on the quality of services for children.  

12VAC35-46-200

By removing the insurance requirements of employee having to be bonded and indemnified puts residents at risk.  Lots of children's group homes intermingle funds of the resident/child and the company's funds without appropriate accounting.  Removing this language and not having language that is GAAP puts the resident/child at financial risk and is not protecting the resident.  

CommentID: 227304