13 comments
This Very(too) Large Manual is packed full of good information, but overwhelming for any employee to open up because of the size. I hope the chapters are visually separated - the Virginia codes could be ommitted.
It has some great information and it is obvious A LOT of work was put into this manual. Chapters 7 and 8 are the most beneficial. The WaMS information should be somewhere else - in it's own separate manual. The flow charts are excellent.
thanks for all your hard work
My concern is that the document is too large and contains information from so many different areas, that it will be near impossible to keep updated. Once people lose confident that they are getting the most current information, they will stop using it as a resource.
These concerns and comments are posted on behalf of both Loudoun County MHSADS and VACSB DS Council.
Appreciative of the work to develop a comprehensive manual for Support Coordination. One overarching concern is the commitment and responsibility of ensuring the manual remains updated as information is updated. Who is responsible for updating the information? Is there an automatic review schedule? How will the manual be kept up-to-date?
There are instances where the information provided in the manual is confusing and/or contradictory to other information in the manual or guidance previously provided. Here are the concerns noted related to content:
Page 14: Gives an overview of the DOJ settlement ruling, but doesn’t say what, if anything, it has to do with support coordination or give any indication of why it is included in this manual.See comment below related to Page 65.
Page 43:The Segway from talking about dignity of risk, confidentiality, etc. into LifeCourse is abrupt.
Page 50: Why is support Coordination overview chapter 2? Shouldn’t this be Chapter 1?
Page 54: Support Coordination Process overview: I think this would make sense if it were the first thing in the chapter, before the different types of support coordination. I think this would make more sense.
Page 56: Goes from recognizing limits in support coordination right into mandated reporting and serious incidents/Human rights abuse, and then into the importance of documentation. Does not flow well.
Page 58: Indicates it is the Support Coordinators responsibility to follow up on CHRIS reports from private providers.While we agree, the Support Coordinator is responsible for assuring known risks are addressed (while at the same time understanding an individual’s right to dignity of risk and person centered planning), DHBDS licensing and Human Rights are the receivers of the CHRIS reports.The system is designed for notification to DBHDS of injuries and allegations, not notification to the support coordinator.If the intent is to notify specific support coordinators, the system needs redesign.Further, these should be explanation of DBHDS’ role. Even the way the “case manager reports” are set up in CHRIS present real concerns as noted below:
Support Coordinators have to log into the system to find information.With other responsibilities, this is not something that can be done on the daily.
The “Case Manager” report can only be run by date range, not by individual.
This presents some HIPAA/ethical concerns of every support coordinator in an agency seeing information about those they are not assigned the support coordinator.
The report is cumbersome to sort through to find out if there is a report for an individual.
For larger CSBs, the resource needed to pull the report, manually divide by individual and then by Case Manager is an unrealistic responsibility.
The “Case Manager Reports” do not provide enough information.After all the work of pulling and sorting the report, you are left with the individual name, date of incident and then that it is a serious injury.No other information is provided.
Page 65:
This addresses the settlement between the USDJ and the commonwealth. It would make more sense to put the overview of the DOJ ruling, from page 14, here rather than where it is currently located.
Bullet point 3 says that an individual’s case manager shall meet with the individual face to face every ninety days. It then says the visit must occur at least every 30 days. This wording is confusing.
Page 78: Enhanced Case Management Flow chart. This chart is not clear.
Page 324:This indicates Support Coordination responsibility to obtain a copy of the MCO HRA and Individual Care Plan.However, it does not indicate who or how the Support Coordinator is to find out who the care coordinator is or who to contact if there are issues with receipt.It also should be clear the MCOs have the responsibility to reach out and collaborate.
Page 867:The Assessment section indicates the Annual Risk Assessment is only completed on non-SIS years.This is in contradiction to recent information provided from DHBDS regarding responsibility for completing annually/to have no more than a year apart from last completion.This needs clarity.
The manual lacks information regarding the important considerations and requirements. Thus, information about the following should be added to the manual.
Based on recent emphasis and audits, add information that Risks Identified in the Annual Risk Assessment must be addressed in PCP or noted why not addressed.
Add that if a Risk on a previous Annual Risk Assessment is no longer identified, there must be documentation of why it is no longer a risk. This is based on recent DMAS QMR audits.
There is little information about HCBS Waiver and the link to information about compliance efforts.Although this is not a direct Support Coordination responsibility, it is important to have links on where to find more information, etc.
In its current layout provided on the Town hall website, the information presentation is often repetitive and has much information which could be better placed in an appendix. The manual itself does not begin until page 35. Below are examples of information that is repetitive or may be better placed in an appendix.
Page 15: Glossary of acronyms. Maybe it would be better to put this in an appendices at the end of the manual?
Org Charts, Employee Directory, etc.:Better placed at the end of the manual as an appendix.
Page 83: Introduces forms, such as the training center post move monitoring report. Does not flow well. This could be in an appendix.
Page 90: this begins the WaMs user guide. Again, this could be a separate document or in an appendix
Page 217-220: This is just definitions of different types of developmental disabilities (autism, CP, etc.).This should be an appendix.
Page 228: This is a chart of neurodevelopmental disorders. Could be put in an appendices. This is repetitive after just reading definitions of all the different developmental disorders.
Page 230: Appears to be a PowerPoint about how consent is obtained. This is directly after several pages on consent, legal guardians, authorized reps, etc. It is repetitive.
Page 302: This is a study that was done on supportive decision making. Is this really appropriate for the manual? This could be a link or in an appendices.It also contains several blank pages
Page 333: This begins a sample of all the different forms that SC’s are to complete. This could again be in an appendices.
Page 338: This is an overview of the use of psychotropic medication for DD individuals. This could be a link to the article. It is also sandwiched in the middle of the samples of forms to be filled out (including the same forms but in Spanish) which is a strangle place to put it.
Page 378: This is a Waiver slot committee volunteer application. Again, could be a in an appendix
Page 397: This is a SIS user guide; make part of appendix
Page 490: This is another PowerPoint on decision making and consent. It is repetitive
Page 565: This is the Supportive Decision Making Study, again
Page: 654: This is a flow chart on the DDA support team referral process. This has been covered many times in earlier parts of the manual and is repetitive
Page 657: This is the WaMS user guide again.
Page 657-932 just appears to be a repetition of earlier information including the WaMS user guide, information about the DOJ settlement, and information about enhanced case management that was presented earlier.
These are additional comments regarding the manual as an addendum to the comments posted on 1/15/19.
Thank you for the opportunity to submit comments for this document (ADDITIONAL COMMENTS TO ENTERED UNDER A SECOND ENTRY)
Page 12: Recommend starting the Introduction with "Use of the Manual" (which is currently on page 14)
Multiple Pages: If org. charts and specific contact information is included in the manual, DBHDS will have to commit to keeping this information current. If this assurance is not made, suggest not listing individuals but rather titles and roles and refer users to the DBHDS website for current information. (This assumes that the website will be current.)
Page 26: This is the only real reference to REACH services. Recommend that this be linked from page 73 also.
Page 43: Are SCs supposed to know what LifeCourse is? Perhaps a better subject heading would just be "LifeCourse" (vs LifeCourse Beliefs and Tools) and then go into what it is, the beliefs and tools. Additionally, it just doesn't flow well where it is placed; consider putting the Community section first and then introducing LifeCourse, since some of what LifeCourse is about is the planning calendar and incorporating natural supports.
Page 53:References ECM applying to individuals on the DD Waiver Waitlist that have the CCC+ Waiver, as well as people on the DD Waiver Waitlist who are eligible for Medicaid. This requirement may be burdensome for SCs with large caseloads of children.
Page 62 (Apeals RIghts): States: "An SC may need to assist a person to request an eligibility appeal..." Is this the SC's job? Might this present as a conflict of interest for the CSB?
Page 78: If onine viewing only this is probably fine. Otherwise, ECM flowchart does not print correctly.
Pages 229-301: Including this PowerPoint presentation without the talking points might not be as helpful as intended and thus information could be easily misconstrued.
Pages 315 - 319: This chapter is largely about soft skills needed to be a good SC. While probably the most relevant to SCs, it seems random following all of the regulatory language and documents included before it. In addition, it seems to end abruptly.
Page 322 (under Eligibility for Support Coordination): Does or should this section differentiate between ID Support Coordination and Developmental Disability "Coordination"? While the criteria is different for ID vs other DD diagnoses, the eligibility for Support Coordination is the same independent of the diagnosis.
Page 322 (under the heading "Diagnostic Eligibility" and the first sentence): suggest adding the word "developmental" ahead of disability. It is not "any" disability that limits a person's ability to live and work independent that makes him or her eligible for Support Coordination. It is specifically a DD and thus this should be clarified in the first sentence of this section.
Page 322 (under the heading "Diagnostic Eligibility"): This section is silent on adaptive functioning as it pertains to diagnostic eligibility.
Page 324 (under Risk Assessment): In the middle of the paragraph the term "Annual Risk Assessment and Fall Risk Assessment" is used. Recommend this term be changed to Annual Risk Assessment to match the rest of the section.
Page 325 (under the section entitled, "Priority Needs Checklist," first paragraph and last sentence): "Priority status is based on how much and how quickly someone is in need of help." This seems a broad and rather subjective statement and can be easily interpreted by any number of SCs to mean something different. Specifically, "how much" of WHAT? "how quickly someone is in need of help"? Should this be "how quickly the individual is in need of DD Waiver services? To ensure that people are appropriately placed in the Priority 1 assignment based "primarily" on objective criteria this sentence should be clarified and written in a manner that gives more concise instruction.
Pages 325-326 (and wherever else referenced in the manual): Recommend consist use of terms when referring to "wait list" -- there are at least four different references used in one section (Chapter 5) for this topic. They include: "Wait List," "wait list," "waitlist," and "waiting list."
Pages 325-326: included in the "Key Points to Remember" at the top of page 326, and with the "point" that begins, "Those assigned with a Priority two. . ." the abbreviation for the Family and Individual Supports Waiver should be identified as "FIS" and not "IS."
Page 332: Recommend that the third box be a VIDES box since this is the decision point between the two processes. Recommend moving the current third box "Documentation of Choice between Inst...." under the "Meets VIDES criteria..." box. Recommend that in the "Meets VIDES criteria..." box stating that this information should be entered into WaMS.
Page 337: Change first sentence from "ID Waiver services" to "DD Waivers."
Page 338: This overview seems pertinent to individuals with DD as well as ID. Recommend changing it to include all.
Pages 339-341: Recommend completing an indication for each drug.
Page 347: This sample letter is old; it references Level of Functioning and MR/ID. Replace with a current letter.
Pages 351, 355, and 361: Delete "Anticipated start date after 7/1/2018."
Pages 352 and 353: There is a reference to "See pg. 43." This is not page 43 of the SC Manual so it is confusing. Recommend deleting these page number references or otherwise providing clarification for the user.
Page 360 (under In-Home Support Services): Recommend re-phrasing the limitation to clearly indicate what "Support to no more than three individuals" means.
Page 369: Recommend moving "Needed Services" document after the DBHDS letters that are mailed to individuals on the waiver waitlist ( currently pages 372 - 375) since the letters reference this document.
Pages 370-371:These forms are the same forms found on pages 343 and 344. Recommend removing the forms on pages 370 and 371.
Page 380 (bottom of page under the "Waiver Slot Assignment Committee Procedures" section): it reads, "CSBs are encouraged to make use of available technology such as secure video conferencing and conference calling to minimize the need for WSAC members to travel, . . ." Since the CSB staff are not participating in the WSAC meetings, we would not have a need to "make use of" such recommended technology. Is the intent here that CSBs should make such technology "available to the WSAC"?
Page 459 (under description for "In-Home Support Services"): It is worded that this service "typically" supplement(s) the primary care provided by the individual, family, or other unpaid caregiver. Suggest removing "typically" from this description as it suggests that this service could feasibly be delivered outside the context of supplementing a primary unpaid caregiver. In reality, this service can be extremely difficult to deliver without a readily available and "primary" unpaid caregiver. Furthermore, the requirement that there be a "back-up" plan "for times when In-Home Supports cannot be provided as regularly scheduled" seems to imply that the In-Home Supports are primary and that the unpaid caregiver is secondary. This seems to create a conflict within the same description for this service.
Page 460 (under "Personal Assistance): there is no mention that children/youth up until the date of the 21st birthday are not eligible for this service under the DD Medicaid Waiver, but rather via EPSDT. Furthermore, since the manual is intended to be a guide for SCs and other CSB staff, it is recommend that there be some guidance in this section for how to use and refer someone to EPSDT, as well as what forms may be required. This comment is applicable to Private Duty Nursing and Assistive Technology.
Page 462 (under Shared Living): For purposes of the SC Manual, it would be helpful if the role of the SC and other CSB staff, with respect to this service, could be discussed vs. the roles of the facilitator, the individual, and guardian, if applicable. Furthermore, there is no mention that this service requires a facilitator. Explanation of this and the role of the facilitator would be helpful for purposes of the manual.
Page 468 (under "Addiction and Recovery Treatment Services"): Recommend a similar section for addressing mental heath/Serious Mental Illness (SMI) and related referrals. This is especially important (if not more important) since individuals with DD are equally at risks or may present with the same mental health (DSM) symptoms as their non-disabled peers. For people with DD, mental illness is too often mistaken for symptoms or patterns of behavior related to the DD diagnosis and thus mental illnesses are often left undiagnosed and untreated for this population. While most SCs are not mental health professionals, they should be expected to use available resources for making referrals for mental health, when indicated. The manual should not be silent on this topic (and the importance of assessing and making referrals) given the prevalence of mental illness for people with DD diagnoses (while at the same time mentioning the importance of making referrals for substance abuse (also important).
Pages 482-484: This section lays out how to pre-plan and conduct a perfectly inclusive PCP meeting with the quintessential individual who is willing and able to drive and participate in their planning process. The statement, "to which they are able to participate" (pg.482) does quite captures how an SC would go about planning and conducting an inclusive PCP meeting with someone who is does not communicate using words and is unable to choose attendees, uninterested in participating, unable to "drive" the planning process, etc. More guidance about what this could/should look like would be helpful.
Pages 490-562: Duplicative PowerPoint from chapter 3
Pages 563-572: Duplicative study from chapter 3
Pages 657-783: Duplicative WaMS User Guide from chapter 2
Pages 885-888: The list of community resources appears to be helpful; however, it will require regular updates and reviews to ensure the links are still active
Pages 885-889: Recommend adding a short narrative to each link so SCs understand when they may need to use a resource. For example- briefly explain when it would be appropriate for an SC to seek out resources with the National Gateway to Self Determination. Alternatively, recommend listing the resources under certain categories. For example: The Arc of Virginia, National Gateway of Self Determination, and the Parent Educational Advocacy Training Center would be grouped together. If the resources are grouped together than a short narrative for each link wouldn't be necessary. Instead, the narrative would be placed with each category or group.
Page 891: Recommend combining "Why Work?" and "Impacts of Employment". The impacts of employment are why someone would choose to work and the benefits of working/earning income.
Page 892: "Definition of Employment" heading should be moved to the beginning of the section so the reader has a clear understanding of Employment and how it is defined by DBHDS. For example, the DBHDS definition of employment is not necessarily the same as how others would interpret "employment." For example, a SC may support an individual and family who identify a GSE enclave position as "employment" even though the person is earning sub minimum wage. It is important to first and foremost establish DBHDS' definition of employment.
Page 892: Recommend offering a short description for the "Association of People Supporting Employment First"
Pages 895-896: The barriers that are listed under the "Assist" heading are prevalent in the disability population; however, the possible ways to address the barriers are not very realistic, especially in rural areas of the state. For example: local funding is not an option in most areas of the state and self pay is unrealistic for many families and individuals. If the state is going to require SCs to have meaningful employment conversations and expects more people with disabilities to become employed, it would be helpful if DBHDS could provide SCs with more realistic ways to address the common barriers.
Page 896: "Lack of transportation" under the common barriers offers no suggestions or explanations. Recommend saying something along the lines of "absent of waiver funding, transportation services....."
Page 896: "Building a Resume" is under the "Assist" heading. Is DBHDS suggesting that the SC should be assisting the individual with resume development? Is this only absent of DARS support (i.e. DARS is on order of selection) and waiver funding? If SCs are assisting with resume development then should they also be assisting with other aspects of job development? This seems to blur the line between employment support through DARS or another ESO and the role of the SC. Recommend elaborating more on this topic.
ADDITIONAL COMMENTS FROM THE ARLINGTON CSB TO BE ADDED UNDER A SECOND ENTRY
Thank you for the opportunity to comment. on this manual. As said by others, it is obvious much effort was out into gathering information regarding the dutie and responsibilities of support coordinators. My concerns are as fllows:
1) Manual is cumbersome with many internal links, will not be user-friendly and therefore will likely not get used.
2) Information in manual is repetitive and many pages could be out-of-date before it is published - who will keep it updated.
3) Information may be better divided with use of appendices and items noted for hisotrical reference vs. information needed for current operations. In addition clarity is requested re:
p 52 - No definition of "short term or special need" as it relates to targeted case management
page 71 - defintiion needed for injury, serious injuries and crisis - assumption made that it will follow OHR definitions?
p80 and p824 - One page notes determination of stable for enhanced case management purposes require documentation by licensed medical professional - but not stated on subsequent pages. Clarity needed
p326 - should second line read "FIS" waiver vs "IS" waiver?
p 327 and 381 - different instructions re: what to do when a slot is available - p327 says CSB contacts WSAC facilitator, p 381 states CSB will contact regional support specialist
p 331 - need clarity around service authorization requests currently reads "SC completes SAs for environmental mods, PERS and assistive technology as the provider". What about CSBs that do not provide this service? What about providers who provide these services and have an NPI number and bill for these services?
Thank you for the opportunity to comment
Jane
ADDITIONAL CHAPTER COMMENTS
Pages 813-814 "Status of Current Risks and Identifying New Risks": Reference pp 881-882 under areas the SC should pay close attention to; p816 "Enhanced Case Management": adding medication changes - make sure that the DOJ reviewers definition of ECM is included in this section; p822 "PCP ISP Updates": suggest adding DMAS 225 when transitioning between providers/initiating and terminating services
Page 832 "Transfer Protocols to/from Other CSBs": a discussion of exceptions such as CSB MOUs/regional agreements, discussion of local funding/resources availability as it pertains to the CSB, discussion of what is to be transferred to another CSB from the EHR for consistent transfers; adding the SIS as something that needs to transfer along with the part about WaMS -- it would be helpful to reference the attachment pp 849-860 at the end of the chapter
Page 834 "Moves to Different Level of Care" states "such as a move from the family's home to a group home" - should it read "other community placement to include a group home, apartment, etc." to go along with the LRE principle?
Page 835-836 "Death" - referencing the emergency regs/Level III incidents and following CSB policies such as sentinel reviews/root cause analyses per their individual policies.
Page 867 Support Coordinator's Role in Health and Safety": A discussion about MH and DD seems to be missing in regard to co-occurring disorders, the importance of regular medical monitoring for medication side-effects, etc.
Page 867 the "ASSESS" tab seems to leave out seizure protocols, skin integrity protocols, wheelchair protocols, etc., - these seem as important as "fall risk assessments
Page 896: Under the “Plan” section it is recommended that a sub header of “career planning” is added before the sentence “The SC’s role is to help”
Page 897: In the “Monitor” section it would be helpful to make the green text into a flow chart instead of putting the information in a text box.
Page 898: The paragraph after the green text in the “Monitor “section does not fit in the section. The paragraph discusses self-advocacy. It is recommended that this entire paragraph be moved to the “Advocate” section.
Page 900: Public Transportation/Travel Training: Recommend changing NOVA to Northern Virginia
Page 900: Links only cover areas of Northern Virginia and Richmond. Recommended that DBHDS works on adding additional links/resources for the rest of Virginia
Page 901: Vehicle Modification: This section offers very limited information, but could be extremely helpful to a SC. It is recommended that additional information is added to better explain this process. Does personal vehicle include a family vehicle?
Page 901, Misinformation about Employment and People with Disabilities: Add a link to VAACCESS in the text box about benefits. Benefits are complicated and SC’s should have a basic knowledge but have the resources available to refer clients and families to professionals.
Page 902 Employment Services Under Waiver: The list after the sentence “All three waiver provide:” is missing community coaching.
Page 902 Employment Services Under Waiver: Add definitions to the three waiver services (unless defined somewhere else in the document)
Page 902 Employment Services Under Waiver: Add additional text to define and explain “Work Place Assistance.” This waiver service is underused; primarily because it is difficult to find a provider that offers the service and SCs are not familiar with the service. The manual should better explain this service. If the service is explained elsewhere in the manual, consider adding a page number to the section.
Pages 909-910 ‘What are Employment Services? What can I expect”. From the way the Q&A reads it appears that this information would be relayed from SC to parent/guardian. Recommend indicating this information at the top of the document.
Pages 911-912 “Employment Options Discussion”. The example employment conversations downplay the difficulty that SCs have with linking clients to appropriate employment services. Recommend adding example 4 with the same context as Example 3 but changing the outcome to Tana wanting to work. Tana is nonverbal and requires total physical care. Many SCs are faced with this exact situation and guidance on how to best approach employment with this person would be beneficial.
Pages 913- 914 Post Secondary Opportunities: Consider adding information about Woodrow Wilson and services that provide supports in an educational setting.
Page 920, Monitor Whether Services are Achieving Intended Outcome: "No other Waiver services in the home"...do you just mean ""no Waiver services"" in the home?
The SC should make home visits to ensure that the individual continues to be safe in the housing arrangement or to assess if they need supports. Is monitoring rent and utility payments now an SC function? SCs don't have time to monitor rent and utility payments and surely that conversation will not go very well with most individuals over the phone.
SC: ""Hey John, did you pay more rent and utilities on time?""
John: ""Yes.""
The contact with the landlord seems appropriate, but we don't understand the two contacts with the housing program; most housing programs have an annual financial review and not follow-along throughout the year to assess lease compliance."
Page 920, Monitor Whether Services are Achieving Intended Outcomes: The guidance of at least one in-home visit per year is not consistent with ECM criteria of at least every other F2F occurring in the home.
Page 921, Monitor Whether Services are Achieving Intended Outcomes: "Review quarterly reports from the service providers to determine whether service providers that support the individual in the home report changes in the person's housing needs, satisfaction with the housing arrangement, rent/utility payment status, or compliance with lease or housing assistance program requirements." This seems to be a new function for SCs. While some of those elements may be contained in the narrative of a quarterly, the vast majority of provider reports are going to contain information about how the individual is progressing towards their outcomes that were laid out in the Shared Plan. That is what the SC is reviewing on their reports.
Page 921 under SC Training and Resources/Tools: Whatever you are calling something in this manual is what it should be called on the DBHDS website. You write please use one of the links to access the above resources, but when you click on the first link it has nothing to do with the 4 bolded tools you just wrote about and when you click on the second link there is nothing called "Support Coordinator Checklist" and two of the other three bolded headings are called something slightly different.
Page 930 under DBHDS Office of Licensing: Include link to regulation
Page 931 under DBHDS Office of Human Rights: Include link to regulations
Page 932 (under DMAS): Add a section on DMAS Integrity Unit reviews
Page 932 under DOJ Settlement Agreement Independent Reviewer
GENERAL COMMENTS
The manual does not explain DARS and the referral process in enough detail. Many SCs are left wondering about the order of selection: what it is, how to know when DARS is on order of selection, the various categories within DARS, and funding limitations associated with DARS.
In general, the manual downplays the difficulty that SCs face with getting clients linked to employment services. The idea of “employment first” means that people with more complex disabilities and challenges are being encouraged to “work,” but the manual does not provide the correct or adequate resources to guide SCs in supporting these individuals and families.
Add information about DARS Customized Employment (CE) and how SCs can access this information and make referrals to the service. Is the service covered by Waiver? If not, then add additional resources to assist SCs with navigating CE without the assistance from waiver.
The document appears to be set up as both a linear document with a table of contents and page numbers, as well as an on-line resource. Recommend not treating it like a physical manual.
Use consistent terms. For example, Virginia is referenced as the Commonwealth, Virginia, and the State of Virginia in one document.
Place a date on every form, guidance memo etc.
Both electronic health record and services record are used. Use one term only to minimize confusion
Ensure all ID, MR language is removed when referring to DD (unless ID language is pertinent; MR language is never pertinent and should be removed.)
Separate the body of the manual from the resources and have appendices A – Z.
Throughout the manual some attachments are dated and others are not. Recommend that the manual consistently date the attachment to ensure the SCs are always viewing what is most current
The manual would be easier to read if there was an appendix of attachments to refer to versus clustering all attachments at the end of each chapter (many of the attachments repeat in different chapters)
Recommend consistent language of authorized rep/legal guardian, case manager/support coordinator throughout the manual
Several tables added to the manual are difficult to read/cut off beginnings and endings of words within the boxes
When discussing individual choice making sure that this includes the legal guardian - ex. p 832 - when making a request for a new SC it only states "when a person requests a change in SCs" and not when the guardian wants a change.
Overall, the manual is chocked full of useful information.And, it is helpful to be able to find all of this info in one place.That said, the volume of this document presents as extremely overwhelming for supervisors and managers to review.We can only imagine how overwhelming the presentation of this massive body of work would seem to a Support Coordinator, especially a new SC.The material is not well organized and thus presents as fragmented in its flow. Lastly, there are numerous grammatical errors throughout the document.
Thank you for the work on this manual. Overall, give direction on the way the manual is to be used. It’s assumed this would be a “handbook” for Support Coordinators and would specify the main aspects of the job and the regulations we must follow. This first draft appears to be a very rough draft, fonts and voice change throughout as if written by different authors. There is too much repetition and the flow of the chapters and information appear to be choppy. There are inserts, and information embedded into the chapters that appear to be in draft forms. Chapter 2 should be scaled back to only very basic information (similar to the One Page Descriptions of the DD Waiver) and referencing where in the following chapters more in-depth information can be found.
Support Coordinators occasionally work with individuals in nursing facilities who have OBRA funding a, and at times review and report on PASSR reports. The manual needs to have a dedicated chapter to what the expectations are in responding to the PASSR reports, the process to request OBRA Funding, how to work with an individual using OBRA Funds and the role/responsibility of the Support Coordinator in working with OBRA. (Basically we support someone one with OBRA Funds as if they are SPO but receive the funds up front, the SC assists in securing the recommended service i.e. day support and transportation and works with the provider to set up billing for the funding…..) List of comments:
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Page 14: The overview of DOJ settlement doesn’t explain the “settlement”. Too vague. |
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Page 15 and 16: Inconsistent formatting. |
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Page 18: Chart is difficult to interpret |
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Page 19-24: For all the contacts need to have consistent usage of punctuation. |
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Page 19-24: It would be helpful to have an explanation. For example, “Contact CRC when…..” in a very small font at the top of page 19 would be helpful. |
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Page 26-28: Instead of listing every county, insert a map with the areas color coated |
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Housing contact information is repeated later. |
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Page 38: “Issues of safety…” bullet covers a lot of information, break it down into sub-categories. |
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Page 38- 42: values/practices defined are basic to the field of human services/social work. Topics seem like common sense in this field and need no further clarification |
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Page 39: the suggestions for learning about cultures sounds insulting. |
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Page 43: using everyday language seems like common sense. |
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Page 44: The lifecoursetools.com link will be helpful! |
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Page 44: The length of the “community” definition excessive. |
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Page 50: “billed activities” should be defined here. |
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Page 52: Section Targeted Case Management is confusing. Need to add a flow chart. |
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Page 52: Mental Health and Substance Abuse Section – include a sentence in each section referring to agency’s guidelines about primary service provider. |
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Page 53 ECM Criteria last paragraph of who it applies to contradicts page 53 second paragraph of who ECM applies to. |
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Page 53: Post Move Monitoring – need directory for the contacts of PMM staff. |
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Page 54: Choice of Support Coordinator- include more information per Emergency Regs regarding the Regional Contract for private contracted case management. |
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Page 56: Monitoring/Evaluating – discusses that periodic site and home visits are conducted- include language “ announced and unannounced site and home visits”.. |
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Page 56: Transitions/Transfers – Include a reference to the finalized Transfer Protocols |
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Page 57: Mandated reporting info. Repetitive |
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Page 57: Require Mandated reporter training. Specify how to access, how often staff need to take the training etc. Add APS/CPS Hotline |
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Page 57: DARS and APS- Include DARS role in APS cases |
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Page 59: Add the SC should be treated with dignity, respect, free from abuse. |
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Page 60: Documentation – specify importance of documentation. Refer to chapter 7 for detailed information. |
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Page 60: Documentation should have own chapter with timelines. Reference importance of documentation, records management, refer reader to agency policy/procedures. Reference use of EHRs and its interacts with WaMS. |
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Page 64: CM Operational Guidelines- no introduction to section, Include a finalized copy. |
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Page 83: PMM Report – out of place add to PMM section or appendix |
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Page 90: Remove WaMS user guide. Add link ore Resource Appendix |
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Remove blank pages 303, 305, 307, 312 and 313, change font on page 311 push to another page, reduce pages. |
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Decision making PowerPoint is repeated. Information needs to be presented by a qualified professional, remove, offer webinar and insert link to webinar. Add presentation to appendix. |
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Manual has too many hyperlinks. Manual should be a quick reference for staff. Hyperlinks can break and information gets updated. All resource information should be put into Appendices for easy replacement when updated. |
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Page 218: ID originates before age 18? Or 21? |
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Down Syndrome makes it sound like the majority have Down Syndrome. |
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Page 221: Information about medications affecting communication and removing meds. Concernings statement, could be misinterpreted and encourage someone to stop taking medications. |
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The author of this chapter should provide their name and qualifications. |
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Expressive and receptive communication is repeated on page 221, |
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Page 222: communication tips good information. |
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Page 223: Role of Family, Legal Guardian, etc. this section out of place, Page 223 -227 and then page 228 is a list of diagnosis.. In the Substitute Decision Making section –there is confusion about ARs. When transitioning from training centers, is a new AR required or another determination process? Include process? |
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Page 223, family and friends. clarify consent is needed for talk to parent of adult child. |
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Information about guardianship and substitute decision put in one place, refer back throughout the manual don’t repeat |
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Repeats information in chapter 1. Combine this information with an introduction or overview of PCT. |
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Information is too basic, include statement from an individual or advocacy group on what is important or how individuals want to be treated. |
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Information is repetitive of required online training for new SCs. Delete section,require the online version. |
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Page 322 states “Developmental Disability Coordination” Define term, use consistent terms. |
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Page 322: Eligibility for Part C Support Coordination: Not all CSBs/BHAs provide this program. |
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Page 322: Diagnostic Eligibility, be clear; functional eligibility for intake and VIDES are two different things. |
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Page 323: DD and TCM Some CSBs provide non billable case management to DD population who don’t qualify for DD Waiver waitlist. |
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Page 324: The Emergency Regs don’t state need for Annual Risk Assessment/Fall Risk Assessment for waiver waitlist. |
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Page 324: References collaboration with MCO Care Coordinator, obtaining HRA and migrating risks, clarify roles. Doesn’t occur at the MCO level for everyone... |
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Page 325: 2nd paragraph states “…can’t be awarded a CL or IS Waiver…” Should Say FIS Waiver |
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Page 325: 3rd paragraph states “For the BI waiver, … if no one in a lower priority category has requested independent living.” Should this say “a higher priority category”? |
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Page 325: Clarify that DBHDS is sending the Choice of Waiver forms annually, not support coordinator. |
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Page 325: DBHDS sends “Needed Services” Form with Recipient Choice Form- include information on this form, how often it’s updated, is it only a DBHDS form, what is responsibility of SC? |
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Page 325: False statement under waitlist: “everyone who requests DD Waiver services is added to the waitlist”. Not everyone who requests is found to be eligible. |
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Page 325: No mention of the 30 day requirement to be on wait list if offered slot. |
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Page 325: Include information about Facility Slots, qualifications and how to obtain one. |
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Page 328: Emergency slot request, reviews decreases in needs with waiver change, but does not review an increase in need (FIS to CL or BI to FIS) |
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Page 328: Review/Update VIDES- add timeline, updated within 6 months of enrollment into waiver per emergency regs. |
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Page 329, physical exam needed within 12 months of receiving a waiver, add when medical needs change. Simplify |
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Page 329: Choice Protocol- add for Support Coordinators including Regional Contracted Case Managers |
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Page 331: Retaining Slots – Requirement for SC send a DMAS 225 to DSS notifying of no waiver service within 30 days? Include information here and in DMAS 225s section. |
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Page 332, nice visual but not all Individuals are eligible for Medicaid; therefore not all Individuals can receive SPO. |
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Page332: Separate ID and DD individuals and SPO services- billing and services are confusing. Need more information about what specialized services are, billing difference, etc. |
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Pages 338-342 remove; present in a training by a qualified physician. Include what a support coordinator needs to know and when to refer to physician |
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Pages 349-365 should be condensed with information in Chapter 6. List waiver services with description once. |
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Provide list of documents with hyperlink in appendix instead of attaching forms. |
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Page 391: Request for Emergency Slot and referral to RST – clarify process as per Emergency Regs |
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Pages 397-441 the SIS User guide, don’t attach, add link. |
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Based on recent ASCEND webinars, need updated manual. |
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Description of waiver services repeated. Include in this chapter and remove all other sections. (remove 349-365 ) |
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Intro is choppy, hard to follow. Include all waivers for SC for resources (Tech Waiver, EDCD, etc) add eligibility and how to access |
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Section on Waivers seems out of place, add to Intro Chapter 1. |
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History of Waiver- remove |
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Clarify introduction, clarify differences between CCC+ and DD. |
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Description of Waiver Services – include eligibility information here or refer SC to section of manual. |
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Resmove blank pages |
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Page 442: DMAS 225- Annual DMAS 225 for those on Waiver, not in emergency regs. |
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Page 449-450: services under the waiver move to appendix |
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Waiver Services – Clarify use of waiver with EPSDT services. |
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Clarify Time Limited Services ex. Community Coaching can’t be ongoing-state this in the description. |
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Page 459: In Home Supports- clarify what portion of service has to be provided in the home. |
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Page 463: include information regarding family as sponsored residential provider. |
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Page 466, clarify difference ins waiver that offers alternative services to people on the waitlist. Add inability to have both, Add section about transitioning between CCC+ waiver and DD Waiver. |
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Page 467-cover MCOs one time in the manual, don’t repeat. Information sounds like SC will only work with MCO when Individual has CCC+ Waiver. An Individual on the CCC+ waiver may/may not qualify for DD Waitlist. |
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Page 468: Add Mental Health Supports |
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Remove power point on Substitute Decision Making. Offer training on this, provide information there. |
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Repetitive information |
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Reference Person Centered Practices, inform SCs to attend training. Don’t repeat training forms. |
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Page 486: Much is covered in Person Centered training! Repetitive. |
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Page 486-487: Writing measurable goals, too wordy. Use bullets to be concise, give examples of measurable goals. Covered in other trainings and should be a reminder, not a repeat of training. |
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Page 487: Need to include outcomes a Support Coordinator would use. Example “________receives supports as stated in my plan” What does that look like? Section appears geared towards providers |
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Page 487: each CSB/BHA have their own required timelines for client documentation. Refer SC to agency’s requirements. |
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Page 487: There is a Box under Person Centered Reviews titled “Required ISP Documentation” appears out of place |
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Page 489: Service authorizations should only be covered one time. Wams user guide is repeated. |
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Page 489: Regional Support Team- misplaced, doesn’t flow with chapter. |
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Provide link to WaMS user guide |
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Eliminate pages in manual by removing documents given in person centered training. Add link to appendix, remove from manual. |
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Page 490-574: Remove. |
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Page 575-637: Remove pages from chapter place in Appendix, |
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Page 638- 2018 Person Centered ISP Guidance- Add to resource section/appendix. SC should not be expected to train or correct providers. |
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Pages 650-654 good to have but says to hover over the titles for a narrative - doesn’t work, there are comments in red asking questions appears to be a draft not a final version…finalize. |
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Page 656: Information on RST misplaced, should come before pages 654-655 |
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Page 658-783: WaMS User Guide –repetitive, remove, place in resource/Appendix section. |
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Service authorization guidance – useful, add link or to resources/appendix |
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Page 811: Last sentence: should state “… direct or in person contact … on behalf of the Individuals… “ |
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Page 812: TIMELY referrals, include timeline, open to interpretation. |
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Page 813: “Actively observe the person and service providers…” Clarify, observe in person and the interactions? Or does through reviewing plans, phone check ins, etc (not face to face)? Open to interpretation. |
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Page 813: Visiting worksite but intrusive... offer alternative methods to monitoring workplace, one sentence says to monitor all aspects of client’s life and next sentence it says don’t be intrusive. |
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Page 813: Face to Face visits state every other in the home- reference Emergency Regs. |
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Page 814: Skin Breakdown Presentation-make this part of the CM Modules. Its good information, good place for staff to understand own role. |
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Page 814: Add change in hygiene or personal appearance to bullet points. |
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Pages 814-816: Face to Face visits state every other in the home- reference Emergency Regs. |
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Page 816: “Review the need for ECM on a regular basis…” Include link to updated information. Section on ECM criteria is confusing when determining eligibility for ECM. Referencing SIS responses/scores which could be 2-3 years old doesn’t determine current needs. |
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Page 816: ECM Criteria last paragraph of who it applies to contradicts page 53 second paragraph of who ECM applies. |
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Page 819: “Extended vacation” how is this documented by SC when visit is missed? |
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Page 820: Chart doesn’t print well. Words cut off. |
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Page 823: ECM flow chart – doesn’t print well, difficult to follow. Could be a great resource if flow was easier to understand |
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ECM criteria can be subjective. CSBs differ in who may meet criteria, Need a clear checklist or one pager to determine ECM criteria. |
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ECM Guideline – there are still many questions that need to be finalized before this is added to the manual. For instance – multiple crisis – how many is that? Interruption of Services – if someone has an interruption (say lack of in home staff) but continues to have day support and/or supported employment is this ECM? Or is it NO Waiver services at all for over 30 days… |
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Page 821: PCR information is repetitive, out of place |
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The format is good, should be modeled throughout entire manual (category, brief explanation, link for the specific regulation or manual) |
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Page 852: Transfer Policy- in draft, finalize and place in resource/appendix section. |
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terminology “mental retardation” in transfer procedures needs updating. |
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There is reference to modifying transfer procedures manual. Finalize |
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Add requirements for psychological evaluation when transferring CSBs. |
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Add information about transitions between private/contract Case Management to CSB Support Coordination. |
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All embedded resources need it’s own section… |
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Need section in chapter about Dual Diagnosis (I/DD and Mental Health). |
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Page 867: Do SCs ever get copies of the CCC+ assessment? Could this be loaded into WaMS instead? |
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Page 869: Proactive Steps to Health good! |
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Page 871: Listing reputable sites to check med side effects-helpful. |
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Page 873-876: Eight Health Risks very useful; however, should some of these topics be linked to SIS and exceptional medical needs? Or is this a resource the case manager can give to others? |
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Page 881: Include legal involvement. Ex., “Past or current legal charges/involvement? Changes to probation?” |
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Page 882: Add CO detector to list. |
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Page 883: Chart is great. |
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Page 883: Qularant audits list 8 types of abuse be consistent with Qularant information. |
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Chapter is focused on health but not much is related to safety. Include more focus on overall safety of clients, DSP, SCs, etc. |
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Remove repeated information. Put contact information here remove from other sections. The link is good. Title it Contact information and community resources, or add to appendix. |
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Page 894: Add “Are there personal care needs?” to questions for considering employment. |
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Include Support Coordinators must have consent before talking with providers, employers etc. |
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Good information, but not specific to Support Coordinators. Information may be included in a Supported Employment Manual, but not relevant to SC. Example: page 896 building a resume, this not something a SC would do. |
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Page 898: Discuss with Individual that they may not always be 100% happy in their jobs… Must be mindful of the SC role to assess satisfaction with services. The SC is required to give Provider Choice if the Individual expresses dissatisfaction. |
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TOO MUCH REPETITION. |
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Page 900: Medicaid non-emergency transportation, the information in this section is misleading and inaccurate. The manual needs to be realistic with the lack of transportation to and from work. Suggest that the person call their MCO to discuss employment transportation, or that the caregiver may need to provide transportation, especially in rural areas. |
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Page 903: Like the 1st paragraph clearly explaining the SC role in benefits planning, very good. |
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Page 909: “what are employment services and what can I expect?” who is this for? Is this supposed to be a resource for the SC to give the Individual/Substitute Decision Maker? |
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What if DARS says the Individual is not eligible for work, but the Individual wants to work? Address this and provide alternative options. If DARS is the gateway to work, then include what the Individual can do if she/he/team disagrees with DARS. |
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The FAQ section is good, but repetitive. |
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Page 914: also reference local parks and rec programs |
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Remove the blank pages!!!! |
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This is a very good section. Focuses on the role of the Support Coordinator in clear terms. |
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Page 927 repetitive, information is on page 30 |
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Remove page 926, put this link on another page (change the font so it fits) |
The 932 page manual has good information, but is too long for anyone to absorb in a reasonable amount of time. If it is the expecation that Support Coordinators need to know all of this information, then it must be phased in over a year long period. I would suggest implementing the critical tasks first and then proceeding with additional duties. As an organization, any requirement which has the CSB teaching this to support coordinators in less than an eight month period will contributie to significant recruitment and retention issues.
Page 487 - ServiceSource proposes an increase in the provider grace period from 10 to 15 days after the end of the quarter to complete their PCR and submit it to the SC. The proposed change would ensure that the SC would have 15 days in which to complete their own PCR, after receipt of the providers’ PCRs, still within the 30-day grace period for the SC’s PCR. This change would create parity between the grace period for providers and SCs. The perttinent text from page 487 and the proposed change are as follows: "Quarterly, the SC will complete a Person Centered Review (PCR). This will include not only progress on outcomes for which the SC is responsible, but also a summary of the PCRs received from all service providers. Because of this, a provider has a 10-15-day grace period after the end of a quarter to complete their PCR and submit to the SC, then the SC has a 30-day grace period after the end of a quarter to complete their PCR."