In the Definitions' section, questions related to "Independant Review Committee", I question how independant the committee will be if it is appointed by the provider. Also, will the committee be compensated for their time and level of expertise? If they are compensated, who will pay? If the committee members are volunteers, how will they be recruited? I also want any "Independent Review Committee" to include peers (those who have received services) and family members of peers. To create a provider appointed group that excludes peers and family members from the review process is unconscionable and flies in the face of a recovery centered system of care.

I think the person affected by the proposed behavioral treatment plan should be able to express their concerns directly to the independent review committee with the assistance of the Human Rights Advocate, if desired by the person. I also think the Human Rights Advocate should be available to the committee to help ensure that the proposed plan is in compliance with the human rights regulation.

 12VAC 35-115-110 Renistate section 8, I strongly believe all proposed restrictions should be reviewed by the LHRC prior to implementation.

12VAC 35-115-105 I strongly believe all Behavioral Treatment Plans must be reviewed by the LHRC proir to implementation and be subject to regular review by the LHRC.