105-20 Definitions

Definition of Missing - Further clarification is needed for this definition as it relates to all services. The definition seems broad. For example; If a person is expected to arrive at 10:00 for an appointment and they no show and we are unable to reach them, are they missing? If they no show for a second appointment is that missing? For individuals in outpatient services living on their own this information would not be timely.  It is recommended to narrow the focus to residential and day services.

Definition of QDDP - The definition of QDDP seems to be different in the draft licensing regulations than in the waiver emergency regulations and the waiver definition. The emergency regulations are more flexible for providers since it allows a substitution of experience for education whereas the licensing definition requires a BA,  MD or an RN.  Many providers have supervisory staff who have extensive  experience  but may not have completed their BA or their degree may not be in a human services area, suggesting for consistency, to use the same language as in the waiver emergency regulations.

105-160 - Reviews by the dept and added required reporting - Regulating that every serious incident must have an identified solution to mitigate its reoccurrence may not apply all incidents, for example; deaths as a result of natural causes. Level III, how will we do a root cause analysis for incident that are not on our premises, as many Level III situations may occur that way. For example; if a client dies in a car accident, how/would we do a root cause analysis of this situation?  The requirement to complete a root cause analysis should be changed to complete a root cause analyses when patterns or trends occur.    

105-400 - Criminal background checks and registry searches - Requiring a disclosure statement from the applicant for pending charges for any offense is not something we would be legally able to ask.