Virginia Regulatory Town Hall
Department of Behavioral Health and Developmental Services
State Board of Behavioral Health and Developmental Services
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10/30/19  1:48 pm
Commenter: Christy Collins, Collins and Collins, Inc.

12 VAC35106-300 Employee training and development

1.  Required initial training within 7 business days is impossible.  This agency contracts with an outside vendor to conduct our First Aid and CPR.  Additionally, we contract with an agency to provide our medication management.  We are at the mercy of these agencies and many times, especially the medication administration is only offered quarterly. 

C.  All employees, contractors, students and volunteers shall complete an annual training that shall include:

                1.  Retraining of all the elements required within 12VAC35-106-120

Another example of an unfunded mandate.  This would be an exorbitant expense for this small agency.  Currently, to bring a full-time DSP/Program Coordinator on board, the expense to this agency is approximately $1900 per employee in current mandated and best practice trainings.  This agency typically has turnover of 5-6 full-time DSP/Program Coordinators per year.  The cost of bringing on a part-time DSP is approximately $1,500/employee with this agency hiring between 5 and 6 part-time DSP’s a year.  Additionally, with the required competencies, our Program Coordinators are spending approximately 10 percent of their time to mentor employees to determine competency areas costing the agency approximately $10,400 year in just salaries.  Annually, we would have to increase our current training protocol by approximately 44 hours per employee at a cost of approximately $18,480.  This is based on straight wages where in reality, this would probably be overtime for the majority of our full-time employees.  Also, this figure does not include the number of hours that services would have to be cancelled or scaled back due to lack of DSP to cover individual’s schedules.  That cost would be approximately $5,000 a year additional.  There is very little small providers can continue to absorb with training that does not seem necessary by our proven track record. This expectation needs to be rethought and this agencies recommendation would be to spend time with provider on a CAP to determine training in areas that are lacking for that specific agency INDIVIDUALLY.

CommentID: 76758