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Virginia Regulatory Town Hall
Department of Behavioral Health and Developmental Services
State Board of Behavioral Health and Developmental Services
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1/17/19  6:50 pm
Commenter: La Voyce B. Reid on behalf of the Arlington CSB

SC Manual Comments II


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" 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



  1. 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.

  2. 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.  

  3. 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.

  4. 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.

  5. Use consistent terms.  For example, Virginia is referenced as the Commonwealth, Virginia, and the State of Virginia in one document.

  6. Place a date on every form, guidance memo etc.

  7. Both electronic health record and services record are used.  Use one term only to minimize confusion

  8. 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.)

  9. Separate the body of the manual from the resources and have appendices A – Z.

  10. 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

  11. 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)

  12. Recommend consistent language of authorized rep/legal guardian, case manager/support coordinator throughout the manual

  13. Several tables added to the manual are difficult to read/cut off beginnings and endings of words within the boxes

  14. 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.

  15. 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.