Virginia Regulatory Town Hall
Department of Behavioral Health and Developmental Services
State Board of Behavioral Health and Developmental Services
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10/8/19  3:22 pm
Commenter: Citizen

3 comments and a typo

12VAC-106-830:  First Aid it Accessible:

Pretty sure that's supposed to be First Aid "Kit" Available.  Or maybe First Aid "IS" Available?  

12VAC-106-790:  Swimming Pools:

Most local health departments are not going to come to a facility to inspect a swimming pool.  They are far less likely to come to a residential location to inspect one of those pools either.  The alternative is a swimming pool business.  What constitutes a "swimming pool business?"  A place that sells pools?  What are they inspecting for?  Holes?  Disease?  Functioning filters?  This overly vague requirement is bound to leave licensing specialists to their own devices when it comes to interpretation.  

12VAC-106-740 C:  Personal Necessities:

Where to begin... "diapering?"  "diaper pail?"  Babies wear diapers.  Adults wear incontinence briefs or receive support with maintaining clean incontinence supplies.  

It's obvious whoever wrote this was only thinking of children, which is why #4 of that reg says folks shall wash their hands after assisting children and themselves in the bathroom.  

"Toileting" is another word you could do without.  

12VAC-106-680 F: Physical Environment:

Very much support the additional 10 degrees Fahrenheit in water temperature.  Not only will that be easier to maintain in older hot water heaters, it will be a more comfortable shower for many people who have historically complained of being forced to take cold showers.  There will surely be arguments made for even hotter water allowances but this is a welcomed step towards a person's ability to choose.

12VAC-106-580 C (iii):  Risk Management

Staff competency "through testing" isn't very clear.  Does this refer to the arbitrary General/Medical/Behavioral/Autism competencies?  Or does this mean competency in a sense that the employee can do the job duties assigned to them in their specific service area?  

Wouldn't both of those things just be the training record and employee evaluation?  What are we testing here?  I can understand testing Human Rights, First Aid, CPR, Crisis Management, Safety Drills, etc.  But there are so many other tasks an employee will be proficient in that aren't going to be tested.

Could the language say "documented staff competency" to allow for orientation and review checklists, staff meeting minutes, staff supervision notes, seminar/workshop attendance sheets, etc?  Otherwise the tests you're going to get are going to be meaningless because they're going to be written to take as little time as possible.  And if a provider isn't going to take a test seriously, it isn't much of a stretch to not take the material seriously.  


CommentID: 76535