Page 2: "...residential Providers are responsible for individuals 24 hours a day and therefore are reuqired to report all incidents once notified." This shifts the resposnbility of licensed non-residential providers, e.g. day support, etc.from reporting what has occurred under their supervision, which may also cause them to shift the repsosnbility of  seeking medical care for the individual. Obtaining  accurate infomration about an incident that occurred with another provider, especially if they didn't report it or take it seriously, can be challenging for the residential provider.

Page 3: Hosptial admissions: I agree with  comments of others that " admissions for the purpose of observation" should not require reporting.

Page 3: Ingestion of any hazardous material: I would suggest amending the language to indicate the incident is reportable as a Level II incident if the provider seeks emergency medical care for the individual after consulting Poison Control or EMS.

Pg.4 Providers should not be required o report Level III incidents that did not occur on their premises or under provision of their services.  DBHDS should notify all providers after receiving the first report to avoid duplication.

Page 7: Third paragraph in the box is too prescriptivr and expands the regulation.Sponosred residential providers should not be relieved of this duty. They are overseen by licensed agencies.