Thank you for the opportunity to submit comments on behalf of Community Living Alternatives and the men and women we support.  We appreciate the work that has gone into improving overall safety, quality, and competence through these amended draft regulations.  

We do have concerns in the following areas:

Page 7:  The definition of "Missing".  Some of the adults we support do have the capacity to make decisions on where they would like to go and the manner in which they will go.  While we make every effort to help individuals communicate their plans with us and build a rapport where we are knowledgeable of a person's patterns, whims, and interests.  It may not be possible to know exactly where someone is 100% of the time when they have the ability and capacity to decide to walk home instead of take the bus or stop off at 7-11 delaying their arrival home by a "reasonable" amount of time.  Requiring a Level II incident be completed for anyone who is not where they are supposed to be at any time is not only unrealistic, but also not person centered or demonstrative of the dignity and respect that the individuals we support deserve.  We ask that you amend this definition.

Page 11:  Serious Incident, Level I is not clear.  

Page 18 160-e:  Requiring Root Cause Analysis of all Serious Incidents will be an excessive burden on a provider of CLA's size.  While we do applaud the effort to better assess how and why serious incidents occur in order to prevent them from re-occurring, some incidents are fairly obvious in their cause and accidental in nature with little that can be done systematically or personally to avoid them in the future.  Creating a report in addition to the current reporting standards for any serious incident will add an additional task to our already stretched Compliance team.  If this remains a requirement, we would ask that there be some consideration for additional funding to meet this mandate.

Page 20, 400:  Background Checks.  Our industry is in the midst of a significant shortage of DSP staff to provide adequate staffing.  Extending the length of time to hire a staff member will only increase this staffing crisis.  We are diligent about conducting background checks and acting immediately on any that come back as ineligible for hire (which has only been 1 in the past 14 months), but having to wait to offer a position until those checks are returned would surely result in potential employees securing employment elsewhere before we could hire them.

Thank you for your consideration.  

Susan Keenan