22 VAC 42-11-810.F.6--Medication should be administered consistent with the 22 VAC 40-72-670 and the Board of Nursing approved training for medication administration; i.e. the recording of "actual time" in the proposed standards is not considered as an industry standard.

22 VAC 42-11-10 Definitions – Please change the definition from “Confined in Post-Dispositional Program” to “Post-Dispositional Program”.  In addition, this definition should reflect the wording of section 16.1-284.1 of the Code of Virginia.

22 VAC 42-11-860 - Behavioral Supports should not apply to detention facility.  The focus of a correctional facility is not therapuetic, but a matter of safety and security to the child and community.