VAC40-61-120 Reports of abuse neglect or exploitation Section B--This requirement should be deleted as oft times it is the contact person or legal representative who may be the subject of a report to Adult Protective Services. This requirement could put the client or ADHC staff at risk of retaliation for the report. Notification should be left up to Adult Protective Services to protect both the client and ADHC staff. VAC40-61-260 Physical Examinations and report Section 8-c--The requirement for the physician to state anything other than the recommended therapy is unrealistic and would be a burden for staff to follow up with if not complete. Physicians often recommend Physical Therapy etc. and it is up to the families to make the arrangements for whatever is ordered. The physician is not necessarily aware of who the arrangements have been made with. This information would be better noted when the Center assessment is completed, and the family can relay the information rather than trying to connect with busy physicians who may or may not have the information. Section C Subsequent evaluations--This paragraph should be eliminated. (section D should remain) The requirement of an examination should not be required for discharge of a participant. Often physicians are very busy and would not necessarily see problematic behaviors that the center would be seeing. Families at times are in denial and do not want to move a participant along the continuum of care to the next level of care, with this being the case they may not relay information to the physician that would enable him to realize the true issue. Also, an additional examination could be a financial burden as insurance might limit coverage for examinations, and the care giver would require time taken off from work to take the person to the physician. It should be up to each center to determine if they are safely able to care for the participant, and as long as this is properly documented this should be sufficient. VAC40-61-380 Transportation Services This section is problematic in that we are required to ensure the requirements listed even though transportation may be provided by various insurance providers who contract their transportation out to companies that we have no control over. Section B would be particularly problematic as some of the companies have been using taxi cabs, and Lyft or UBER drivers. Centers have no way of determining if the drivers have proper training, CPR certification or first aid training. It would be burdensome for the centers to try to determine this for every driver and every trip. If the center provides their own transportation this would be feasible, but with so many different providers it would be nearly impossible for the center to remain in compliance. VAC40-60-480 Rest Area Clarification is needed for section C--Many centers utilize recliners for their rest area and in their clinics to provide rest or for someone who becomes ill. Would those centers be required to utilize the stated linen requirement? Many of the centers do not have laundry facilities and would either be required to refit the center with plumbing to meet this requirement, or would have to contract with a laundry service in order to be in compliance which would be burdensome financially.