P37,106-310, B. The provider shall notify the department of any changes to policies required by this regulatory chapter prior to implementation of the change. This requirement is overly broad as policies often contain agency specific content and may lend itself to various interpretations and expectations by specialists.
P 39, 106-380, C The provider shall submit their regular business hours to the department. Too vague – when should this be done, to what part of the Department. There are several other references in the draft to “the Department” For example 106-440. Would suggest specifying Licensure, Licensing Specialist, etc.
P44, 106-490, A. The provider shall maintain the following emergency medical information on a completed face sheet. EHRs do not have face sheets (definition?) and this requirement seems relevant for residential and day program but not outpatient services.
P47, 106-550, 5, 5. A prohibition on staff visitors. This seems directed to a specific type of provider. How would outpatient clinics do this and why should they?
P51, 106-590, C-E. Each provider shall establish and maintain licensing complaint handling policy for all other complaints under this chapter which specify: A system for logging receipt, investigation, and resolution of licensing complaints; Format of the written record of the findings of each licensing complaint investigated; Designated staff responsible for licensing complaint resolution, In addition to the information required by 12VAC35-115-40, the provider shall also provide each individual receiving services and, if applicable, his authorized representative, with the name, mailing address, and telephone number of the: Provider’s complaint contact person; and The contact for the department’s Office of Licensing, The provider shall maintain documentation of all licensing complaints received and the status of each licensing complaint from date of receipt through its final resolution. Records of licensing complaints shall be maintained for no less than three years. It is difficult to distinguish this from the Human Rights regulations related to complaints – and the wording of this seems to indicate that we are to investigate our own complaints. This entire section is confusing and seems to replicate human rights regulations.
