Is this political in nature? Why is the only Heightened Scrutiny on your page the Vanguard Landing?
DMAS. Seriously. Please. There are HCBS Settings violations GALORE across this commonwealth of ours. I've had experiences with 3 Tidewater group homes & 1 sponsored residence & 1 "community integration" program.
The violations are in plain sight. Not hidden. And not dumb (like the rule about no company shirts you cite - that is just overreach, anti-team building, anti-personal choice, unless it is just a ban on uniforms - no one is out there not realizing someone has a disability because staff isn't in a company t shirt!!).
Forget your 'power & control" system-based standards. Look at the ones on choice & independence. They are ROUTINELY violated all over. I have reported directly to your very WEAK human rights division at least 3x on HCBS settings violations & behavior management violations. Crickets. Literally nothing is done.
Across Virginia we have for profit orgs, staffed by close relatives of each other (translation: with HUGE conflicts of interest!!!), running homes & programs. Setting bedtimes. Denying kitchen access. Making up their own rules. Providing pretend choices, not real ones. Using people's belongings to control their behavior.
Heightened Scrutiny? Just go ask these folks. Ask them what happens "if they be good". Ask them what happens "if they be bad".
You do nothing about it. You just create more complicated bureaucratic paperwork to perpetuate your own system, addressing paper violations while real ones are commonplace. So, yeah, heightened scrutiny isn't for one big org that gets your goat. It is for all the providers you are letting get away with routine violation of human & civil rights.