Definitions: Informed Choice.  "These options are developed through collaboration with ...the provider ....." and 660 C. "the provider shall explain to the individual ..... alternative service or services that might be advantageous for the individual......"  Discussion about what options an individual has in the community is incumbent on the CSB Support Coordinator prior to placement and then at least annually or when indicated.  If an individual has already been admitted by a provider and an ISP is being developed, decisions about supports have already been made.  If an individual is interested in alternative supports, it is more reasonable to expect a provider to discuss supports offered by the provider and then to refer the individual to the CSB Support Coordinator to discuss other providers.

400

Considering staffing is already a state-wide issue, requiring providers to obtain results of criminal background check and registry searches prior to hiring applicants will delay hiring and escalate the challenge of adequate staffing.  Additionally, due to 2-6 week return of results, most DSP level applicants will not be able to wait to secure the position.

520

A. "who has training and expertise in conducting investigations, root cause analysis, and data analysis"--by what criteria will this training be established?  

C. "Uniform risk triggers and thresholds as defined by the department" should be defined in the regulations.