Agencies | Governor
Virginia Regulatory Town Hall
Department of Behavioral Health and Developmental Services
State Board of Behavioral Health and Developmental Services
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1/18/19  12:32 pm
Commenter: Fairfax- Falls Chruch CSB

Comments to Draft of SC Manual
  1. Length of the document is overwhelming and some contributing factors are repetitive information already located elsewhere in the manual. Remove duplicate slides and /or pages so that the document is condensed  Perhaps removing the duplicates slides and /or pages helps condense the document.
  2. Ensure that the links to chapters- “to at a glance” work- none of them currently does.
  3. Use consistent language/verbiage thru the document e.g. when referring to Legal Guardian use Guardian or Legal Guardian consistently, not both.
  4. Update outdated information across the manual: page 66, 871- incorrect information about Waivers in VA; -Not all forms and guidance documents are the most recent/up to date, e.g. the appeal letter listed includes old language- it still contained the Urgent/Non Urgent language vs. Priorities;
  5. Ensure that Links to external information are   working directly from the manual opposed to copy and paste the link into a browser.  Some of the links indicate:” page not fund”. E.g. page 154, 224, 315, and 450.
  6. Page 16 power of attorney =POW- incorrect abbreviation.
  7. Page 48,57, -DARS abbreviated as DARs
  8. Complete chapter :“Required Documentation for Individual Service Plans” –page 650- 653
  9. Add to the chapter: “ Transfer of Protocols to/from other CSBs” - page 832-list  detailed information regarding transfer documentation  needed/required when  transferring individuals between CSBs- e.g. list documentation needed to the Waiver recipient transfer; none waiver and wait list /monitoring status.
  10. Align information with Emergency IDD Waiver manual and clarify where there is 10 days grace period for face –to face visits or not. Emergency IDD Waiver manual does not have the 1 0- days grace period.
  11. Clarify whether SC needs to complete Fall Risk Assessment and if so how often.
  12. Include information about using email, texts etc. for collateral contact and clarify whether the mean of communication is permit able to  use  for collateral contacts.
  13. Clarify statement on p. 324 regarding individuals on wait list needing risk assessment- risk assessment is required only for individuals who are on the waiver.
  14. Slot retention- incorrect information on p. 331 regarding slot retention request is needed if services are interrupted for 60 days but isn’t this required at 30 days without services?
  15. Environmental Modification section- elaborate in detail regarding modification to the home when the individual resides at the group home or with paid caregiver at home.
  16. Overall, the SC Manual has good information and have informative links; many of the chapter‘s introductions are quite helpful.
  17. Outdated information leads to the main questions, will the document be updated as things change (especially with all of the specific contacts/people’s positions? Who is responsible for updating? How often will the document be updated? Will CSBs have input into the updates?