While there is a great appreciation and importance of ensuring that incidents a.) get reported and b.) get reported in a timely fashion, there are serious concerns about the ramifications being instituted by DBHDS through this proposal. 

With all of the reform that is happening in Virginia, it is concerning that DBHDS has chosen to:
1.) implement changes to a process that currently yields a 90% compliance rate
2.) shift the historical stance of DBHDS from a department that wants to support providers and assure quality through a collaborative process, to one that wants to penalize providers……because of a time-sensitive reporting process that may not even be seen by DBHDS for days.
3.) implement a process that will have an unfair impact on larger providers. They are serving more clients and have more employees, which natural increase the probability of such an incident occurring. Doesn’t seem fair.
4.) implement, yet not define when the 2 year reporting period begins and ends.  Is this at first incident? Do the time frames refresh when a license is renewed? How will this work?
5.) disregard a protocol for special circumstances that can be reviewed and considered to amend a citation (i.e., situations beyond the control of the provider).
6.) encourage providers to fear DBHDS rather than work together to improve the lives of the people we serve.
7.) not understand that this will impact the providers who are serving clients well, and understand their ethical duty to report….better late, then never.  This will not hinder the providers who are not reporting incidents at all.
8.) begin implementing this progressive citation protocol on June 15, 2020, before responding to the concerns that are presented through the Virginia Regulatory Town Hall process.

Again, it is important to ensure the reporting of incidents, and most providers are constantly working to get better.  At the end of the day we all want what is in the best interest and safety of our clients, families and employees. Let’s consider the level of care being provided before taking licenses for administrative burdens. Thanks for your consideration.