To whom it may concern:

I have reviewed the "Draft ISP Guidance" that has been open to public comment. I do understand that change is inevitable. Change has always been the only constant that I have encountered during my tenure I have had the privilege to work in this field providing Virginia based DSP and Supervisory services for 12 years and have been exclusive to Virginia as a DSP and Residential Service Coordinator for the past almost 5 years. By explaining this, I understand the struggle of the amount of documentation that is required from different perspectives.

The basis of what I have reviewed seems very similar to “the old way” of how we collected data. I will admit, the “If/then” format of the Outcome statements makes complete sense to me. I feel like that sentence structure is straight forward and gives DSPs a clear path to what is expected of them in terms of measurability and the type of data that needs to be observed in order to have a clear and concise picture of progress in the people whom we/they support.

Unfortunately, if this new process is implemented as explained, DSPs will be asked to yet again increase the amount of daily documentation that is required. It is to my experience that when paperwork or the amount of documentation is increased, less time is able to be spent with the people whom we support to ensure that they are able to pursue a meaningful path to a life like ours. In essence, the person-centered approach regresses due to the demands of paperwork.

In my opinion, the last thing any new documentation process should do is take time away from the people whom desperately need our quality time OR to place a more unmanageable work load on those whom are trying to implement an exceptional standard of quality of care to those same people.