Virginia Regulatory Town Hall
Department of Behavioral Health and Developmental Services
State Board of Behavioral Health and Developmental Services
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10/31/19  3:52 pm
Commenter: Rappahannock Rapidan CSB

Comments - Part 2

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Regulation #


RRCS Comments



Full Time and Part Time Employee Records – Degrees/Training History

Recommend changing this to allow 3rd party vendors for education verifications. Many providers use vendors, rather than obtaining official transcripts.



Full Time and Part Time Employee Records – Job Related References

Three job related references may be difficult for younger individuals or those who have been in positions for a long time. Recommend changing this to two references.



Full Time and Part Time Employee Records –

Verification of Employment History

Recruitment is a difficult process for the CSB's as a whole. The time and effort that goes into sourcing, screening, and hiring is time consuming. The process that we currently employ is very time consuming.  On average, it takes between 5 to 10 days to conduct references, run background checks, etc.  Adding another component to this process will prolong the process.  In addition, the past governor decided to remove questions concerning the criminal history of an applicant from the state’s application.  Thus, if he removed the question due to his belief that agencies would use that information to subjectively rule out candidates, why would we want to verify everyone's work history.  What is the purpose of the requesting the information? What is the added benefit of the information? 



Full Time and Part Time Employee Records – Timely Filing

Results of required criminal background checks and registry searches of founded complaints of child abuse and neglect; results shall be placed within a file within three business days of being received by the provider.


Recommend changing this to 10 business days to allow for Human Resources (or other appropriate staff) to review the results and act on them.


The Dept. should also provide guidance about how they expect this standard to be documented.



CommentID: 76821