Given the notarization requirement for advance directives to be registered under this program should there not also be an educational component mentioned in the regulation, such as through the Virginia Bar Association, or the Virginia Chapter of the National Academy of Elder Law Attorneys.  Also, should consideration be given to broadening access to the registered advance directives to other providers of health care services, such as rehabilitation facilities, home health care organizations, hospices, assisted living facilities, and emergency medical service providers?  Also, were Do Not Resuscitate forms purposely excluded from registry under the new program?  Lastly, who would have authority to remove an advance directive from the registry after the death of the registrant?

We are very concerned with the narrow scope of health care providers that are allowed access to this registry.  Clearly the legislation addressed the development of a registry in the context of individuals with terminal illness.  As drafted neither hospice nor home health organizations which are licensed by the Department of Health are allowed access. We strongly urge the Department to amend the regulation and allow a broader number of providers the ability to access this information.  Hospice and home care organizations must be allowed access to the registry given the nature of the servcies they provide in the community.