12VAC35-105-460. Emergency medical or first aid training:  Requiring in person training is restrictive when there are many excellent online trainings available.  Request that the in person requirement be removed.

12VAC35-105-320. Fire inspections:  Sponsored residential should not be included in the requirement to have an inspection from a fire marshal.  Fire marshals will often refuse to visit a family home.  This could significantly delay homes being able to open, thus preventing individuals from having access to less restrictive housing options.  Standard fire precautions such as requiring fire extinguishers is sufficient.

The classification of all service settings within this single regulation is not reasonable. Sponsored Residential services should be excluded from this requirement.

12VAC35-15-160 D 2:  “For all other Level II and Level III serious incidents, the reported information shall also include the consequences or risk of harm that resulted from the serious incident.”  It is reasonable to present consequences that occurred, however, potential risks are difficult to identify without medical training.  It is also highly suggestive.  Recommend eliminating the language “or risk of harm.”

12VAC105 – 440:  “15 days to complete orientation”:  This is an extremely tight time frame that will be impossible to meet in many instances.  Medication training, for example, can take four full days and is scheduled through a nurse – this can take time.  Having a requirement this stringent will limit the pool of available workers to provide impotant services.  Recommend removing the requirement for completion within 15 days and putting in place a more realistic time frame such as 45 days.