12VAC35-105-520. C

Suggested Language:

C. The provider shall conduct systemic risk assessment reviews at least annually to identify and

respond to practices, situations, and policies that could result in the risk of harm to individuals

receiving services. The risk assessment review shall address at least the following:…

4. Use of high risk procedures, including seclusion and restraint; and…

Examples of high risk procedure considerations include the following…

Comment: In addition to seclusion and restraint, what other procedures are considered to be ‘high risk?” We ask that DBHDS clarify and provide examples of “high risk procedures” to reduce potential inconsistencies from individual interpretation.

Supporting vaACCSES Comment

12VAC35-105-520. C

C. The provider shall conduct systemic risk assessment reviews at least annually to identify and

respond to practices, situations, and policies that could result in the risk of harm to individuals

receiving services. The risk assessment review shall address at least the following:…

Comment: Section C would support suggested language change to Section B as it outlines “harm to individuals” (plural) meaning two or more to be systemic. This will allow for a separation between one individual receiving services that needs a risk management review in their person-centered plan vs. systemic risk on the part of the organization.