Risk Manager Attestation (June 2026)

What changed in June 2026

On June 16, 2026 the DBHDS Office of Licensing issued a revised version of the Risk Management Attestation Form. The revision changes how the Conducting Investigations topic area is satisfied. Beginning July 1, 2026, when a provider hires or designates a new Risk Manager, the provider must use the updated form.

The revision affects one topic area only — the other four (Risk Management, Understanding of Individual Risk Screening, Root Cause Analysis, Use of Data) are unchanged.

The regulation

12VAC35-105-520.A requires every DBHDS-licensed provider to designate a Risk Manager who has completed department-approved training in five areas:

1. Risk management
2. Understanding of individual risk screening
3. Conducting investigations
4. Root cause analysis
5. Use of data to identify risk patterns and trends

The Risk Manager signs and dates the Risk Management Attestation Form. Their direct supervisor signs and dates it as well, unless the Risk Manager has no direct supervisor (there's a checkbox for that case). The form is not submitted to DBHDS at the time of completion — it's kept on file and produced on request during on-site or remote inspections.

The Conducting Investigations change

Before June 2026, providers could satisfy the Conducting Investigations topic area with internal or commercial investigator training. As of the June 16, 2026 revision, the only accepted path is:

DBHDS Office of Human Rights Approved Investigator Training — the Investigating Abuse and Neglect Course Series, delivered as three self-paced modules plus a comprehensive assessment, in the TRAIN Learning Management System. All components must be completed in TRAIN for any person seeking certification as a "trained investigator" under 12VAC35-115-175(F)(4).

Acceptable evidence at audit:

• A current TRAIN Certificate of Completion for the Investigating Abuse and Neglect Course Series, or
• A certificate from a past OHR-facilitated trained investigator training (legacy credentials are still accepted).

The OHR Trainings page is here: https://dbhds.virginia.gov/human-rights-trainings/. It also has instructions for creating a TRAIN account.

What about TrainingHub's Investigating Abuse and Neglect course?

TrainingHub offers an Investigating Abuse and Neglect (IAN) course as part of the default catalog. It is excellent foundational and supplementary training for supervisors, program managers, and any DSP designated to conduct internal investigations.

It does not satisfy the trained-investigator credential under 12VAC35-115-175(F)(4). Only the OHR/TRAIN series satisfies that credential. Use TrainingHub's IAN course for staff orientation, ongoing competency, and onboarding into the investigator role — then send the designated person to TRAIN for the credential itself.

What goes in each topic area on the form

| Topic area | DBHDS-approved trainings (check at least one per row) | |---|---| | Risk Management | Minimizing Risk (April 2023, three sessions), CDDER Risk Management & Quality Improvement (Dec 2020), OL Risk Management: A Presentation for DBHDS Licensed Providers (Nov 2020), or OL Risk Management Regulations: Tips and Tools (June 2021) | | Understanding of Individual Risk Screening | Same Minimizing Risk / CDDER / OL Nov 2020 options as above | | Conducting Investigations | OHR/TRAIN Investigating Abuse and Neglect Course Series — required as of July 1, 2026 | | Root Cause Analysis | Minimizing Risk, CDDER Dec 2020, or OL Root Cause Analysis (RCA) (Oct 2020) | | Use of Data to Identify Risk Patterns and Trends | Minimizing Risk, CDDER Dec 2020, or OL Nov 2020 |

Where to get the form

The DBHDS Office of Licensing posts the current form (and lists the approved trainings with links) on the OL webpage. Always pull the form directly from DBHDS rather than reusing a copy — DBHDS revises it periodically and the version on file must match the version in effect when the Risk Manager attests.

Recordkeeping checklist

• Designated Risk Manager has named and dated the form
• Designated Risk Manager has signed the form, OR their supervisor has signed
• One DBHDS-approved training is checked in each of the five topic areas
• The TRAIN Certificate of Completion for the OHR investigator series is attached
• The signed form is kept on file at the provider site (not submitted to DBHDS)
• The form is presentable on request at any inspection

How TrainingHub helps

• Tracks DSP / supervisor completion of the in-platform IAN course as supplemental documentation
• Lets staff upload external certificates (including the OHR/TRAIN certificate) under Manage → Staff Certifications
• Generates compliance and completion reports that auditors can be handed alongside the attestation form
• The attestation form itself is a state document — keep the signed original on file, with a scanned copy attached to the Risk Manager's staff record in TrainingHub for redundancy.