22 VAC 40-72-10 Definition of high risk behavior-I disagree with the part of the definition that states "such as floor pacing that might indicate anxiety or stress".  If a resident has been on antipsychotics for any length of time, this could be a side effect of the medications or a resident who has Parkinson's Disease.

22 VAC 40-72-70 Risk Management --This provision invites litigation, creates additional liability for the assisted living facility and will be duifficult for the staff to implement.  Leave out all but the first line.

22 VAC 40-72-80 Quality Improvement --Recommend deleting portions of B and C (the examples) regarding self assessment and quality improvement and to change the number of years the document must be retained.

22VAC  40-72-90 Infection Control-Remove all the requirements and leave it to each facility

22 VAC 40-72-100 Incident and Occurrence Reports--Recommend deleting part A

22 VAC 40-72-580 Food Service and Nutrition-Recommend deleting B3, C, D, and F.  Under G recommend deleting the word "automatic".

22 VAC 40-72-810 Resident Councils- Recommend deleting E 3-I This part permits the resident council to work with administration to make recommendations re:  P&P.

22 VAC 40-72-950 Evacuation Drills-Recommend deletion or change frequency to every 6 months and restore to fire drills.