Continued comments (part 2)

12VAC35-106-490  Emergency medical information

Face sheets are generally for paper charts.  Electronic Health Records are now used and emergency medical information is easily accessible. 

A.6 – “…and any medical protocols for those problems or conditions.”   What is meant by “medical protocols” and is this necessary for a provider not providing medical services?  

A.9 – What is the need for having the name of the hospital for delivery?  This seems unnecessary.   Does this information fall under the heading of “emergency medical information”?

12VAC35-106-510  Service Description requirements                     

Suggest that the service descriptions be available upon request. 

12VAC35-106-550  Privacy

5. A prohibition on staff visitors.  What is meant by this?   Please provide further explanation. 

12VAC35-106-560  Transportation

B. 1  requiring annual driving record checks causes an additional administrative and financial burden on providers. 

B. 6.  This seems to indicate that those with a DUI or reckless driving conviction are not allowed to provide transportation to clients.  Could there be a timeframe for these convictions?   Something like, no convictions in the past 5 years on these items?  This regulation may disproportionately affect peers with lived SUD experience. 

12VAC35-106-590  Monitoring and evaluating service quality

C.  Please provide a definition of a “licensing compliant.” 

12VAC35-106-710  Traffic pattern

Most traffic patterns are not under the control of the provider.  This seems unnecessarily onerous. 

12VAC35-106-750   Lighting

Section A.  Artificial lighting shall be by electricity.  This is prescriptive.  Some sites are moving to solar, battery, etc.  Recommend removing this.

Section C.  Lighting in halls – is this just for residential settings?

12VAC35-106-740 Personal necessities

Section A.  It reads as though the program must provide personal hygiene and grooming items.  Is this correct?  How will this be paid for?   Additionally, what is the definition of “service locations where appropriate?”

12VAC35-106-810  Emergency Preparedness and response plan

What is the definition of a “vulnerability analysis?” 

Section D.   For those CSB’s that are a part of a local government, the CSB is included in the emergency preparedness plans of that locality.   Thus documentation of collaborative outreach seems superfluous.

12VAC35-106-820   Access to telephone in emergencies: emergency telephone numbers

Section A.  Most landline telephones still require electric.