106-20: Please ensure definition of ES (Crisis Intervention) is consistent with Project Bravo and DMAS’ definitions.  

106-20: Please update OP service definition to account for DMAS allowance for outpatient to be billed in smaller increments of time.

106-20: Please update definition of serious incident—unplanned psychiatric admission to include other forms of advance planning in addition to WRAP. Please provide clarification that a “planned psychiatric admission” would be a voluntary admission and should not be considered emergent, requiring CHRIS reporting.

106-20: Please provide clarification regarding definition and guidance on reporting suicide attempts. Guidance document that was issued specifies suicide attempt “with intent to die” must be reported; however, who makes the determination of whether there was “intent to die” when determining whether an incident requires reporting. Licensed clinicians and physicians are often times not comfortable stating whether there was an “intent to die” so reporting is occurring for many incidents out of an abundance of caution, resulting in increased administrative burdens such as RCAs and inflating threshold numbers.

106-20: Please clarify how succession planning applies to CSB where there is not a specific, designated “license holder.” Is it referring to members of executive leadership or Executive Director within the CSB?

106-20: ASAM levels should be added to definitions for applicable SU services

106-20: For systemic deficiencies, please clarify “multiple” and how this takes in to account the size and scope of an agency.  

106-30: Should include licenses for ACT (small, medium, large teams)

106-40 D.2: Please include timelines and expectations for DBDHS to respond to applications and other requests.

106-50.2.f /50-3.e: If commissioner lowers a license for any reason, what is the process for appeal and/or due process.

106-60: The two-hour timeframe may not be obtainable particular for providers in rural areas and organizations with paper records that are in storage. Provider should respond immediately and no later than 2 hours with acknowledgment of receipt of request and plan for providing access, but access to documents may not be available for 1 business day.

106-80 A.4 and E.5: Is this requiring that all updates to a service description must be submitted to DBHDS with service modification form?

106.90: Should include timeframes for when DBHDS is expected to respond in writing within 30 calendar days.

106-120: It is important to clarify that not all errors resulting in a CAP should be considered a “systemic deficiency.” In larger organizations, human error does occur despite effective training and systems. Currently, providers are asked to treat each citation as “systemic” even if it is not systemic based on the root cause of the problem. Continually addressing each error as systemic regardless of true trends or patterns results in additional administrative burden and low morale among all staff.

106-120: If all CAPs must include systemic changes and ongoing monitoring, then the CAP itself cannot be completed within 60 days as currently required in the guidance. Further clarification would be appreciated on timelines for the implementation and completion of CAPs and should address that short-term actions may be completed within 60 days but long-term actions may take more time especially since methods of ongoing monitoring must be spelled out as part of the CAP requirement.

106-190 – Please clarify requirement of Executive Director being on premises during regular business hours. If ED is unavailable, what does official designation of another staff member look like? How does telework

106-250-2 – Are organizations required to obtain and maintain copies of high school diplomas as means of verifying high school education? Often times these diplomas are challenging to obtain.

106-250 – Are only Virginia documentation of driver’s license accepted?

106-290 B.1.  Correct to 15 business days

106-290.2.A/B  Please specify that medication administration training is only for positions responsible for administering medications. Also, clarify if this training is required for doctors, nurses, etc.—positions that are qualified based on their formal degrees and training.

 106-300.B. – Please provide clarification what consists a significant change to require updates being sent to DBHDS.  Are these now requiring formal approval from DBHDS or just being informed of the changes.

106-370.C: Who is business hour information being sent to and how frequently must this be communicated?

106-570.C: Consider increasing to 30 business days

106-589: How is competence to be demonstrated? What will DBHDS be looking for?

106-590.G: Duplicative complaint processes between Licensing and Human Rights will be confusing for both consumers and staff.