§20 Definitions – Serious Incident - Hospital Admission

Recommend this definition be changed to “Unplanned Hospital admission”. Hospital admissions can take place as part of a routine or planned medical service; these should be exempt from reporting as a serious incident.

§20 Definitions - QMHP

Recommend the definitions of QMHP-A, QMHP-C, QMHP-E and QMHPMH be revised. The Board of Counseling now defines these qualifications; the Licensing regs should match their definitions

§400 Criminal Registry Background Checks and Registry Searches

We are concerned about the proposed requirement for “the provider shall review the criminal history background check and registry search results prior to hiring the applicant.”

RRCS requests this information in a timely manner during the hiring process but obtaining the results are outside of our control. There are often significant delays with the agencies that process these background checks and criminal registry searches.

Requiring the results before an applicant is hired slows down the hiring process and inhibits our ability to recruit qualified staff.

§160  Reviews by the Department – Root Cause Analysis of Serious Incidents

Requiring a root cause analysis for each serious incident is burdensome to providers. We recommend the requirement for a root cause analysis be limited Level II and Level III incidents.