VNPP Comments on 12VAC35-115

30 - The definition of "Independent Review Committee" should be revised to include " . . . It shall be composed of professionals with training and experience in applied behavioral analysis or other relevant disciplines who are not involved . . ."

The definition should not limit the professional expertise on the committee to one discipline or speciality/theory of therapeutic approach for the obvious reasons that

• something new/better will come along
• the limitation would severely limit the pool of individuals who could participate, and
• ABA is not necessarily the best approach for all circumstances.

60 (B) 1. Would it be wise to remove the listing of basis for discrimination as new items (eg., gender identity) maybe added at some point?

105 (B) Are we confident that we have sufficient "licensed" professionals to complete the assessments?

175 (B) 1. Shall be modified as follows: "Be contacted by the director or designee regarding the complaint within 24 hours of being notified of the complaint but no later than the next business day."

D. Shall be modified as follows:  ". . . all of the requirements of subsections C and E.

G. Add that under the conditions described, the Advocate (a mandated reporter) must report their concerns to the local department of social services either directly or through the state abuse reporting hotline.

230 (A) 1 Would it be wise to add "or other approved system" in case the web based system becomes obsolete?

260 (C) Add as follows: "6.  Review the reports entered into the web based abuse/neglect/complaint  reporting system, resolve outstanding issues with the provider and, if all parties are satisfied, "close" the case within 30 working days of receiving the provider’s disposition or notice of appeal.

Generally the Virginia Network of Private Providers supports the modifications to the role of the LHRCs and the simplification of the complaint process; we believe these changes will support the core mission of the Human Rights system by allowing a focus on the issues that really matter!

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