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.