106-240 Criminal background and registry checks: The provider shall have a policy related to the periodic performance of criminal history background checks of employees and contractors after the initial check performed pursuant to 12VAC35-106-240(A)(1). The policy shall require that the provider conduct background checks on a minimum of 20% of all existing employees annually. Comment:  This will have significant financial and administrative impacts on providers.  Consider changing requirement to all providers must have a policy that addresses criminal background checks, and do not include a required percentage. 

106-300 Employee training, Draft Reg:  Required initial training: Within 7 business days following an employee or contractor’s start date, each employee or contractor responsible for supervision of individuals receiving services shall receive basic orientation and training regarding: a) the provider’s behavior intervention policies procedures and techniques regarding less restrictive interventions, timeout, and physical restraint; b) Cardiopulmonary resuscitation (CPR) and first aid training issued by the American Red Cross, the American Heart Association, or comparable authority in standard first aid and CPR. Comment:  It would be extremely difficult for providers to provide First Aid and CPR training within the first 7 days.  Recommend removing a time frame. 

106-310 Notification of policy changes: Draft: The provider shall notify the department of any changes to policies required by this regulatory chapter prior to implementation of the change. B. The provider shall notify the department of any changes to policies required by this regulatory chapter prior to implementation of the change. Comment:  Notification to OL of changes to policies prior to implementation places undue burden on both OL and providers.  This will slow the process of updating policies to meet the needs of the changing regulations, laws, and agency requirements.