Virginia Regulatory Town Hall
Department of Behavioral Health and Developmental Services
State Board of Behavioral Health and Developmental Services
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10/24/19  1:59 pm
Commenter: Holly Albrite, HRCSB

General Comments
  • P17, Section 106-30, C3 - For non-residential services, the license identifies the maximum capacity of individuals the provider may serve at a given time.  Unclear what this means for non-residential services such as outpatient, case management, etc.  It may be in reference to inpatient services which are alluded to in the prior sentence, but this is not clear.  This requirement is repeated in several other sections including p22, Section 106-80, A11.
  • P23, Section 106-80, E6 . Any changes that cause a provider to be unable to provide services to any individual for a significant period of time. Unclear what scenarios would fall under this category, what is a significant period of time, and encompassing any individual seems overly broad. 
  • P29, Section 106-180 and 106-200 Governance and Executive Director/Administrator These sections are very similar to the Department’s Performance Contract which already dictates code requirements for Boards and Board members. Will smaller providers have the administrative structure to meet these requirements.  How it the requirement The provider shall have a governing body … which includes persons with expertise in management, and finances to be met and measured   
  • P. 33, Section106-240, B3 The policy shall require that the provider conduct background checks on a minimum of 20% of all existing employees annually.  This places an additional administrative and financial burden with unlikely benefit – each employee would only have a background check once every 5 years but to recheck all employees every year would be excessive, expensive,  and still not guarantee an immediate awareness of changes.  B2 is sufficient.


CommentID: 76637